Individuals not domiciled in the United States but who maintain American holdings can be subject to enormous American estate and gift tax exposures. Estate and gift tax is assessable based on fair market value of holdings at time of transfer, and only a $60,000 exclusion is provided for estate tax purposes (with no specific exclusion at all for gift taxes). Proper structuring of asset holdings is critical to avoid these exposures.
For United States individuals with multinational connections, estate and gift tax occurs on worldwide holdings but with a massive exclusion ($12.06M for 2022). Assorted complexities still arise outside of tax imposition – including questions about how other countries will tax transfers/need to properly coordinate considerations across jurisdictions.