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Assume a person that's not domiciled in the US. That person has a US brokerage / trading account (say in Fidelity or Charles Schwab) that holds shares of various listed companies (both US-based and international companies, i.e. non-US based).

In the event of death, would the entire valuation of the brokerage account be considered a US situs asset (for purposes of the estate tax) simply because the brokerage account is held in the US? Or would only the shares of US companies be subject to the estate tax? I can find various definitions and examples of what US situs assets are but I couldn't find that specific case identified explicitly.

It is clear that shares of US-based companies are US situs. My question is about shares of non-US companies which are held in a US-based brokerage account.

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    Can you edit the question (and possibly add a tag) to indicate where the person is domiciled, as that could well be pertinent. Not definitive, but this PDF, touching on UK, US and South Africa, uses the phrase "if [the] Company issuing the shares was incorporated in [XXX]" to determine if equities come under country XXX's version of inheritance tax (suggesting that non-US shares would not attract estate tax).
    – TripeHound
    Oct 8, 2019 at 7:12
  • @TripeHound. I do understand that the general rule may be further relaxed (to the taxpayer's benefit) by the provisions of a bilateral treaty between the US and the decedent's country. I am trying to keep the question relevant to a wider audience hence I am only asking for the general rule, not withstanding any possible further bilateral treaty's provisions. Oct 9, 2019 at 0:38

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I'm not a lawyer but everything I read indicates that the location of the brokerage account is irrelevant - it just depends if the shares are of a US company or not

E.g. https://advisor.morganstanley.com/michelle.ward/documents/field/w/wa/ward-sofia-michelle/Taxation_of_Non_Resident_Aliens__NRAs_.pdf

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