Yes — US citizens are subject to US federal estate tax on their worldwide estate above $15 million (2026, made permanent by the One Big Beautiful Bill Act). This applies regardless of where a US citizen lives, where their assets are located, and how long they have been abroad. Moving to Mexico, Colombia, Argentina, or any other country does not reduce or eliminate US estate tax exposure. No bilateral estate tax treaty with any Latin American country exists to provide structured relief.

No — the US has no bilateral estate or inheritance tax treaty with Mexico or any other Latin American country. The US/Mexico income tax treaty (1993) covers income taxes only. All relief from US estate tax on Mexican assets (or from Mexican local charges on US assets) is via US domestic unilateral credit rules only, which provide limited and unreliable relief.

A fideicomiso is a Mexican bank trust required for foreign nationals to hold real estate in Mexico’s restricted zones — within 100km of any international border and 50km of any coastline, which covers virtually all popular expat destinations (Puerto Vallarta, Los Cabos, Cancún, Pacific coast). The bank holds legal title; the foreign buyer holds beneficial rights. On death, the beneficiary designation in the fideicomiso document — not the US will — governs who receives the Mexican property. A fideicomiso with outdated beneficiary designations (e.g. from a previous marriage) can conflict directly with the current US will.

No — Mexico has no federal inheritance or estate tax. Mexican ISR (income tax) on property gains may apply to non-resident heirs who sell inherited Mexican property. Mexican civil law forced heirship applies to Mexican assets — children, spouse, and ascendants have protected inheritance rights under the applicable state civil code. US citizens in Mexico still owe US federal estate tax on their worldwide estate above $15 million.

No — Colombia has no national inheritance or estate tax. Colombian civil law applies a community property system: the marital community is liquidated first (surviving spouse retains their 50%), then the deceased’s 50% is distributed to heirs. Colombian forced heirship reserves 50% of the estate for descendants (children, grandchildren). Income tax on gains from Colombian assets may apply on disposal. US citizens in Colombia owe US estate tax on worldwide assets above $15 million.

Yes — Brazilian ITCMD (Imposto sobre Transmissão Causa Mortis e Doação) is a state-level inheritance tax at rates up to 8% (a constitutional amendment proposing to raise the cap to 16% was under parliamentary consideration as of 2026). Rates vary by state: São Paulo 4% flat; Rio de Janeiro 4–8%; most states 4–8%. The Brazilian inventário (mandatory probate process) freezes all Brazilian assets for 1–3 years. Brazilian forced heirship reserves 50% for herdeiros necessários (descendants, ascendants, surviving spouse).

No federal inheritance tax. Buenos Aires Province imposes succession duties up to 21.9% for non-direct-family heirs on Buenos Aires Province-situs assets; Buenos Aires City does not. Argentina’s BCRA (Banco Central de la República Argentina) foreign exchange controls severely restrict conversion of Argentine pesos and repatriation of funds. US heirs inheriting Argentine assets may wait years to access and repatriate proceeds, while the US estate tax Form 706 filing deadline (9 months from death) runs simultaneously.

Yes — Chile’s Ley 16.271 imposes inheritance tax at graduated rates of 1–25% depending on kinship and estate size. Chile has the most restrictive forced heirship in Latin America: 75% of the estate is reserved — 50% to legitimarios (forced heirs: children and parents) and 25% mejora (preferential distribution among descendants). Only 25% of a Chilean estate is freely distributable by will. This applies to Chilean-situs assets regardless of the deceased’s nationality or what any foreign will says.

No — Peru has no inheritance or estate tax. Peruvian succession applies civil law rules including forced heirship (heirs forzosos: children, parents, spouse). Peruvian probate (sucesión intestada or testamentaria) through Peruvian courts or a notarial process is required for Peruvian-situs assets. US citizens in Peru owe US estate tax on worldwide assets above $15 million.

The US unlimited marital deduction — which normally eliminates estate tax on assets passing to a surviving spouse — is only available to US citizen spouses. If your spouse is not a US citizen (including Latin American nationals), assets passing to them at your death do not qualify for the unlimited marital deduction. US estate tax above the $15 million exemption is immediately payable. The solution is a Qualified Domestic Trust (QDOT), which defers (not eliminates) estate tax until the non-citizen surviving spouse’s death. This must be established in your will and requires specialist US estate planning advice.

For US citizens: no. The US estate tax return (Form 706) must be filed within 9 months of death regardless of where the deceased lived or where their assets are. Interest accrues on unpaid estate tax from the 9-month deadline. For estates with Latin American assets that are frozen in probate (Brazilian inventário, Argentine BCRA controls), the executor may need to fund US estate tax from US-side liquid assets while waiting for Latin American proceeds to become available.

The inventário is Brazil’s mandatory probate process for all Brazilian-situs assets. It can be extrajudicial (through a Brazilian notarial process — 2–6 months, only where all heirs are adults who agree) or judicial (court process — 1–3 years, required where there are minor heirs, disagreements, or disputed assets). All Brazilian assets are frozen throughout the inventário. Brazilian forced heirship (50% to herdeiros necessários) is applied during the process regardless of what any foreign will says.