Swiss inheritance tax: cantonal, not federal
When you inherit from a Swiss estate, Switzerland does not levy a federal inheritance tax. Instead, each canton sets its own rates and exemption rules. For US citizens, this cantonal layer can interact with US reporting in ways Swiss advisers rarely mention, so it helps to review estate planning for US expats in Switzerland.
- Spouses and direct descendants (children and grandchildren): typically 0% in all cantons
- Schwyz, Obwalden, and Nidwalden: inheritance tax abolished entirely
- Zurich: 6–36% depending on relationship
- Vaud: up to 50% for unrelated heirs
- Geneva: up to 54% for unrelated heirs
The 2023 forced heirship revision: more of the estate can go where you want
Since 1 January 2023, Swiss inheritance law gives the deceased significantly more freedom to decide who gets what. The revision reduced the compulsory portion (Pflichtteil) for children from three-quarters to one-half of their statutory inheritance share, and abolished the compulsory portion for parents entirely. This means a testator with children can now freely dispose of half the estate — up from just one-quarter before 2023.
Why this matters for US citizens: if your Swiss relative died on or after 1 January 2023, the new, higher disposable portion applies — even if their will was written years earlier under the old rules. Conversely, if you are planning your own Swiss estate, the revision opens considerably more room to direct assets to a US-based spouse, to skip a generation, or to a non-family beneficiary without the old forced-share constraints. Existing wills and inheritance contracts should be reviewed: language that referred to the old, higher compulsory shares can produce unintended results under the current law.
US tax side: no federal inheritance tax, only estate tax
As the recipient, you owe no US federal inheritance tax. The US taxes estates, not inheritances, and only estates above the federal estate tax exemption — $15 million in 2026 — are exposed to the 40% top rate. A US citizen's worldwide estate counts for this test, regardless of where you live. The US–Swiss estate tax treaty from 1951 does not provide relief from double taxation on movable US situs assets, so cross-border planning matters.
$15 million
US federal estate tax exemption in 2026
40%
Top US estate tax rate above the exemption
Form 3520: when foreign inheritances trigger a US filing
You must file IRS Form 3520 if you receive more than $100,000 in aggregate from a nonresident alien or foreign estate during the tax year, including amounts from related parties. (Gifts and bequests from foreign corporations or partnerships have a separate, lower threshold: $20,573 for 2026, adjusted annually.) The form is due separately from your Form 1040, by April 15 plus any extensions. Missing it triggers a penalty equal to the greater of $10,000 or 5% of the inheritance per month, capped at 25%.
Do not treat Form 3520 as optional
The penalty for a late or missing Form 3520 is the greater of $10,000 or 5% of the amount received per month, up to 25% of the inheritance. Even if no US tax is due, the filing obligation stands separately from your income tax return.
Swiss probate timeline: what to expect
Swiss probate varies by canton, but generally includes opening the will, identifying heirs, preparing an inventory of assets, and obtaining a certificate of inheritance. Heirs may need a tax clearance before receiving some assets. The timeline depends on the canton and complexity; expect at least several months, and often longer.
Since 1 January 2025, Switzerland's revised international private law (IPRG) has changed the rules for cross-border estates. Under the new framework, the deceased's last residence still determines which country's courts have jurisdiction by default, but the testator now has broader rights to choose Swiss law or Swiss jurisdiction for their estate — a meaningful option for US citizens with assets on both sides who want Swiss probate rather than a US domiciliary proceeding. If you are a US citizen inheriting from a Swiss relative, coordinate with the Swiss notary or executor to understand how Swiss forced heirship rules affect your share, especially if the deceased tried to use a US-style will.
Inherited Swiss accounts and FBAR
The moment you inherit a Swiss bank or investment account, it counts as a foreign financial account for US reporting. If the aggregate maximum value of all your foreign accounts exceeds $10,000 at any point during the calendar year, you must file FinCEN Form 114 (FBAR). This includes accounts you own jointly or have signature authority over, even if the Swiss estate process is not fully closed. File by April 15; an automatic extension to October applies.
Swiss assets that fall outside the estate — and still trigger US reporting
Not everything passes through Swiss probate. Pillar 3a retirement savings accounts and certain life insurance policies with named beneficiaries fall outside the Swiss estate entirely — they pass directly to the designated beneficiary by contract, bypassing both the will and forced heirship rules. But they still land in your hands, and from a US perspective they are every bit as real as an inheritance through probate: a large Pillar 3a payout to a US-citizen beneficiary still triggers the $100,000 Form 3520 threshold, and the received account triggers FBAR just like any other foreign financial account. Do not assume that because the Swiss side treats an asset as outside the estate, the US reporting obligations disappear.
Foreign tax credit: reducing double taxation
Swiss cantonal inheritance tax you pay may qualify for a foreign tax credit against US estate tax under IRC §2014. The credit is limited to the lesser of the foreign tax paid or the US estate tax attributable to the foreign property. It does not offset US income tax, and the old US–Swiss estate tax treaty does not relieve double taxation on movable US situs assets. Work through the allocation with a cross-border specialist before assuming the credit will wipe out US tax.