Sarenco, are you deliberately missing the point? Your statement regarding spouses was blanket when in fact it's only an issue between a US citizen spouse and a non US citizen spouse.
I'm not deliberately trying to miss your point, I'm simply trying to clarify your position.
You agree (I think) that, in general, a liability to US estate tax arises for any non-resident alien on inheriting US assets (including securities issued by a US company) with a fair market value in excess of $60,000. It doesn't matter whether the US assets are inherited from a non-US citizen.
The only reason I mentioned a transfer to a spouse on death (the second part of the sentence that you take issue with) is that such an inheritance would be exempt from Irish inheritance tax and therefore the US estate tax would be a sunk cost.
What am I missing?
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