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Inheritance tax
International tax law distinguishes between an estate tax and an inheritance tax. An inheritance tax is a tax paid by a person who inherits money or property of a person who has died, whereas an estate tax is a levy on the estate (money and property) of a person who has died. However, this distinction is not always observed; for example, the UK's "inheritance tax" is a tax on the assets of the deceased, and strictly speaking is therefore an estate tax. Inheritance taxes vary widely between countries.
There was a steep increase in the number of countries that implemented inheritance taxes throughout the 19th and early 20th century. From 1960 onwards, inheritance taxes declined in prevalence as numerous countries repealed theirs. For historical reasons, the term "death duty" is still used colloquially (though not legally) in the UK and some Commonwealth countries. The estate tax in the United States is sometimes referred as "death tax".
In some jurisdictions, when assets are transferred by inheritance, any unrealized increase in asset value is subject to capital gains tax, payable immediately. This is the case in Canada, which has no inheritance tax. When a jurisdiction has both capital gains tax and inheritance tax, inheritances are generally exempt from capital gains tax.
In some jurisdictions, like Austria, death gives rise to the local equivalent of gift tax. This was the UK model before the Inheritance Tax in 1986 was introduced, when estates were charged to a form of gift tax called Capital Transfer Tax. Where a jurisdiction has both gift tax and inheritance tax, it is usual to exempt inheritances from gift tax. Also, it is common for inheritance taxes to share some features of gift taxes, by taxing some transfers which happen during the lifetime of the giver rather than on death. The UK, for example, subjects "lifetime chargeable transfers" (usually gifts to trusts) to inheritance tax.
Arguments for inheritance taxes include reduction of discrimination between inherited income and income from work due to taxing at different tax rates. Inheritance has been compared to nepotism and inconsistent with the values of capitalism. Inheritance tax has been argued to be preferable to income tax on work or land value tax.
Arguments against inheritance taxes include loss aversion to kinship. Differences in inheritance taxes on trusts and estates of natural persons have been described by one article as inequitable. Georg Hegel viewed families as legal persons, which is reflected in German inheritance laws for family firms.
Some jurisdictions formerly had estate or inheritance taxes, but have abolished them:
Some jurisdictions have never levied any form of tax in the event of death:
Inheritance tax
International tax law distinguishes between an estate tax and an inheritance tax. An inheritance tax is a tax paid by a person who inherits money or property of a person who has died, whereas an estate tax is a levy on the estate (money and property) of a person who has died. However, this distinction is not always observed; for example, the UK's "inheritance tax" is a tax on the assets of the deceased, and strictly speaking is therefore an estate tax. Inheritance taxes vary widely between countries.
There was a steep increase in the number of countries that implemented inheritance taxes throughout the 19th and early 20th century. From 1960 onwards, inheritance taxes declined in prevalence as numerous countries repealed theirs. For historical reasons, the term "death duty" is still used colloquially (though not legally) in the UK and some Commonwealth countries. The estate tax in the United States is sometimes referred as "death tax".
In some jurisdictions, when assets are transferred by inheritance, any unrealized increase in asset value is subject to capital gains tax, payable immediately. This is the case in Canada, which has no inheritance tax. When a jurisdiction has both capital gains tax and inheritance tax, inheritances are generally exempt from capital gains tax.
In some jurisdictions, like Austria, death gives rise to the local equivalent of gift tax. This was the UK model before the Inheritance Tax in 1986 was introduced, when estates were charged to a form of gift tax called Capital Transfer Tax. Where a jurisdiction has both gift tax and inheritance tax, it is usual to exempt inheritances from gift tax. Also, it is common for inheritance taxes to share some features of gift taxes, by taxing some transfers which happen during the lifetime of the giver rather than on death. The UK, for example, subjects "lifetime chargeable transfers" (usually gifts to trusts) to inheritance tax.
Arguments for inheritance taxes include reduction of discrimination between inherited income and income from work due to taxing at different tax rates. Inheritance has been compared to nepotism and inconsistent with the values of capitalism. Inheritance tax has been argued to be preferable to income tax on work or land value tax.
Arguments against inheritance taxes include loss aversion to kinship. Differences in inheritance taxes on trusts and estates of natural persons have been described by one article as inequitable. Georg Hegel viewed families as legal persons, which is reflected in German inheritance laws for family firms.
Some jurisdictions formerly had estate or inheritance taxes, but have abolished them:
Some jurisdictions have never levied any form of tax in the event of death: