Читать книгу Global Residence & Citizenship Handbook - Christian H. Kälin - Страница 24

A change of residence may not only reduce one’s income-tax burden significantly, it usually also has a major impact on the inheritance-tax situation. However, proper planning and advice is particularly important with regard to inheritance taxes, as in many countries the distinction between residence and domicile is relevant in this case. You may well be tax resident in a jurisdiction which levies no inheritance tax, but upon your death your former country of residence may claim that you were in fact still domiciled in that country and consequently may subject your worldwide estate to inheritance taxes. Furthermore, inheritance and gift taxes can also apply to heirs and beneficiaries of gifts (for example in Germany), or to the property that is transferred, and may thus be levied irrespective of the residence and domicile of the deceased. In the case of real property, generally the country where the property is located will tax it. If you own US securities, however, the US imposes taxation upon the death of their owner even if there is no other connection to the US than the fact that the securities (the shares, bonds etc.) are issued by US entities. Trusts, foundations, companies or life insurance structures may be used in such cases to mitigate adverse exposure.