Does Japan tax inheritance my children receive from me in the US?
Short answer: Possibly, on worldwide assets. Japan's inheritance tax reach depends on the residence history of the deceased and the heir rather than nationality: an heir living in Japan, or one connected to a long-term Japanese resident, can face Japanese inheritance tax on assets located anywhere in the world, including in the United States, and there is no US–Japan estate or gift tax treaty to prevent double taxation.
Written and reviewed by Anthony Walsh, Selanis. Last reviewed 2026-10-09.
Why it works this way
Japan classifies taxpayers by whether they or the deceased held a Japanese address within specified look-back periods; a foreign national resident in Japan for more than ten of the preceding fifteen years can bring worldwide assets into scope even after later leaving Japan, while shorter-term foreign residents may be taxed only on Japan-situated assets.
Because there is no US–Japan treaty covering estate and gift tax, a family that is both subject to US estate tax (as US citizens) and Japanese inheritance tax (through residence history) has no treaty mechanism to automatically prevent the same wealth being taxed in both countries; relief, where available, depends on each country's unilateral foreign tax credit rules.
The rules changed in 2017 specifically to address short-stay foreign nationals so that genuinely temporary residents are not pulled into worldwide taxation, but the line between a temporary posting and a long-term residence is exactly where many American families lose track of the calendar.
The expensive mistake: Assuming Japan only taxes what is physically in Japan
Long-term residence — by the deceased or the heir — can bring worldwide assets, including US accounts and property, into Japan's inheritance tax net. Nationality is not the determining factor.
What to do
- Map your and your heirs' Japan residence history — Count years against the relevant look-back periods for both the decedent and the recipient.
- Identify the double-taxation exposure — With no US–Japan estate treaty, work out whether unilateral credits meaningfully offset both taxes.
- Get both a US estate attorney and a Japanese tax specialist involved early — The structuring options differ depending on which side of the ten/fifteen-year test your family sits on.