Jack Holowczak — personal property appraiser, Toronto

U.S. Estate Tax Appraisals for Non-Resident Collectors (Form 706-NA)

USPAP-Compliant · Personal Property · U.S. & Canada

Non-U.S. persons are often surprised to learn that tangible personal property physically located in the United States — art hanging in a New York apartment, jewelry kept at a Miami residence, a handbag collection in U.S. storage — can fall within the U.S. estate tax at the owner's death, even where the owner never lived in the United States.

Executors, foreign counsel, and family offices engage the practice for fair market value appraisals supporting the values reported on Form 706-NA. Engagements are remote, documentation-driven, and conducted through counsel where the estate is represented.

A typical engagement: valuing an art, jewellery, or handbag collection kept at a U.S. residence on behalf of a non-resident estate.

Services

When Form 706-NA Arises. Estates of non-resident, non-citizen decedents holding U.S.-situs assets above the statutory exclusion — historically $60,000, absent treaty modification — may have a U.S. estate tax filing obligation. Tangible personal property physically located in the United States at death is generally U.S.-situs; limited exceptions exist (for example, certain works of art on loan for exhibition), and estate tax treaties may modify outcomes. Whether and how to file is determined by the estate's counsel — the appraisal supports the values reported.
What the Appraisal Provides. Fair market value as of the date of death, or the alternate valuation date where elected, developed from comparable sales in primary auction records and licensed databases, in a USPAP Standards 7 and 8 report stating the standard of value, effective date, scope of work, and assumptions.
Working Internationally. Engagements run asynchronously and in writing with executors and counsel in any jurisdiction. Documentation is exchanged electronically; reports are delivered in U.S. dollars.
Fees. Quoted by engagement letter based on scope of work, time, and complexity; never contingent on appraised value.

Frequently Asked Questions

Is a collection kept in the U.S. exposed to U.S. estate tax if the owner lives abroad?

It can be — tangible personal property physically located in the United States is generally U.S.-situs property for estate tax purposes, subject to limited exceptions and applicable treaties. Whether a particular estate must file is a question for counsel; this practice provides the supporting valuation.

Can the appraisal be completed from outside the U.S.?

Yes. The methodology is remote and documentation-driven, and engagements are routinely conducted with foreign executors and counsel entirely in writing.

What documentation is needed?

Photographs, purchase records, provenance documentation, and any prior appraisals or insurance schedules. The report discloses its scope of work and assumptions in accordance with USPAP.

Is this legal or tax advice?

No. Situs, treaty application, and filing obligations are determined by the estate's counsel and tax advisors; the appraisal supports the values they report.

How much does a tax appraisal cost?

Engagements are quoted by engagement letter based on scope of work, time, and complexity — the number of items, the state of documentation, and the intended use of the report. Fees are never contingent on appraised value.

Is an appraisal needed for the IRS transfer certificate (Form 5173)?

Banks, storage facilities, and transfer agents holding a non-resident decedent's U.S. assets often require an IRS transfer certificate before releasing them, and the certificate process runs through the estate's U.S. filings. A fair market value appraisal of the U.S.-situs tangible personal property supports the values those filings report. Whether a certificate is required in a given estate is a question for counsel.

The items have already been shipped out of the U.S. Can date-of-death value still be established?

Yes. Retrospective effective dates are standard appraisal practice: fair market value is developed as of the date of death from market evidence for that date, wherever the property is located when the appraisal is prepared.

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