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
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. 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. If you are a US citizen, 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.
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.