Estate Tax on Non-resident Alien Beneficiary of IRA

1. We are concerned with mitigating estate taxes on the following USA assets when my wife (non-resident alien/not domiciled in the US) inherits these assets from me:
a. My tax deferred retirement plan in the USA — traditional IRA
b. My tax deferred pension plan in the USA — Profit Sharing Plan funded by my employer.
c. My tax exempt retirement plan in the USA — Roth IRA

The amounts in the accounts exceed the $60,000 exemption for non-resident aliens.

2. Citizenship
a. I am a dual citizen of Israel and the USA.
b. My wife is a citizen of Israel but not a citizen of the USA. She is a non-resident alien, not domiciled in the United States

The US-Israel tax treaty does not address estate tax.

My question is:

• Are any of my plans (Roth IRA, traditional IRA, Profit Sharing plan) exempt from estate taxes when my wife inherits these plans from me?



I doubt that they would be treated differently than your other assets, but this is forum is not focused on estate tax issues. Suggest you check with an estates attorney.



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