Gift tax in the United States
If a person is a non-resident alien for purposes of gift tax, taxation of gifts is determined in a different way. If the property is not located in the U.S., there is no gift tax. If it is intangible property, such as shares in U.S. corporations and interests in partnerships or LLCs, there is no gift tax.
Estate tax in the United States
Furthermore, the estate tax exemption is not portable among spouses if one of the spouses is a noncitizen.
Currently, fifteen states and the District of Columbia have an estate tax, and six states have an inheritance tax. Maryland and New Jersey have both. Some states exempt estates at the federal level. Other states impose tax at lower levels; New Jersey taxes estates beginning at $675,000.