It is of pivotal importance for a testator to consider the tax implications of his or her decisions when drafting a will or preparing an estate plan. There is an appreciable number of states which do not levy taxes against a testator’s estate or the inheritances of the beneficiaries; but there are many more estates which do impose estate or inheritances taxes.  In the context of a cross-border estate, the tax and legal systems of the different states where the assets are located may differ and expose beneficiaries to multiple or adverse tax impacts. The principal risk is that an estate or inheritance will be taxed in more than one state.  It is important therefore to be aware of the taxes that may impact a particular succession and be further aware of the reliefs that may be available to mitigate or eliminate any double or multiple taxation that may potentially occur. Exemption from estate tax or reliefs against double taxation may be available through two different channels: Double Taxation Agreements or the domestic tax statutes of a state. Ireland currently has only two Double Taxation Treaties dealing with the double taxation of gifts and /or estates: with the US and the UK.  The US currently has 15  Double Taxation Treaties which contain gift and / or estate tax provisions. The US also has an Income Tax Treaty with Canada which includes provisions in relation to taxation of estates. The UK has ten Estate Tax Treaties.  Click on the below links for more information on the individual treaties.