Estate tax in the United States subject to a different regime for estate tax than U.S. citizens and residents. The estate tax is imposed only on the part of the gross non-resident alien's estate that at the time of death is situated in the United States. These rules may be ameliorated by an estate tax treaty. The U.S. does not maintain as many estate tax treaties as income tax treaties, but there are estate tax treaties in place with many of the major European countries, Australia, and Japan. U.S. real estate owned by a non-resident alien through a foreign corporation is not included in a non-resident
Legal history of income tax in the United States bonds) was within the category of an excise or duty, and was neither a capitation tax (based on population) nor a property tax. The court also concluded that direct taxes, within the meaning of the Constitution, were only capitation taxes and taxes on real estate. In 1894, a Democratic-led Congress passed the Wilson-Gorman tariff. This imposed the first peacetime income tax. The rate was 2% on income over $4000, which meant fewer than 10% of households would pay any. The purpose of the income tax was to make up for revenue that would be lost by tariff reductions. This was