All U.S. Citizens and U.S. Residents are subject to the U.S. gift and estate tax, even though their property is located outside the United States. A Non-Resident Alien property is subject to taxation if the situs of the property is in the United States. Whenever property is transferred to a spouse who is not a citizen special rules might apply. In the case of estate planning, citizenship does matter. Pay close attention to whether or not it is the donee spouse
Estate Planning