Technical article
Selling an Inherited Home Abroad When the Heirs Live Somewhere Else
The United States gives an heir a cost equal to the market value on the date of death, even for a home abroad.
Picture a widow from Texas whose home in Mexico passes to her son in Canada. He does not plan to move to Mexico, and he decides to sell. Two tax offices now have an interest in the sale. The family and the sale are an example. The rates below are the ones the sources give.
What the country where the home stands charges
| Place | Tax on the sale by a non-resident seller | Other points from the sources |
|---|---|---|
| Mexico | 25% of the gross price, or 35% of the net gain if a Mexican representative is appointed and the deed passes before a notary | The notary withholds at closing. One guide says Mexico does not step up the cost for an heir. |
| Spain | 19% on the gain; one tax summary gives 24% for sellers from outside the EU | The buyer withholds 3% of the price. Plusvalia, a town-hall tax, is separate and due within 30 days (one guide, tier U). |
| Portugal | 50% of the gain is taxed, at rates from 12.5% to 48% for 2026 | One guide (tier U) says the home must first be registered in the heirs' names. |
| Italy | An inherited home is left out of the five-year rule, so the sale is not taxed as a gain | A tax-office ruling says so. |
| France | 19% income tax plus 17.2% social levies, or 7.5% for sellers covered by social security elsewhere in the European Economic Area | Full exemption after 22 years for income tax and 30 for social levies. |
| Greece | Suspended until 31 December 2026 | One guide says 15% when it returns. |
| Colombia | 15% on the gain on a home held two years or more; one guide gives 35% if sold sooner | 1% is withheld at the notary. One guide says the heir's cost is the value declared in the succession. |
| Thailand | A 2% transfer fee, and 3% to 3.3% specific business tax if held under five years, otherwise 0.5% stamp duty. One guide lists inherited property among the exemptions from the specific business tax. | One guide puts the seller's total at about 5% to 7% of the price. |
| Turkey | A gain within five years is taxable. Property that came free, by inheritance or gift, is exempt whatever the holding time | One tax-news site gives this rule. |
What the heir's home country does
The United States gives an heir a cost equal to the market value on the date of death, even for a home abroad. The statute has no condition about where the home stands. The executor may elect an alternate valuation date.
Canada treats a person's property as sold at market value on death, and no estate tax follows. A later sale gain or loss goes on the heir's own return. Spouses can roll the property over at the dead person's cost.
In Australia, the beneficiary's starting cost is generally the dead person's cost at death. Indexation is not allowed for a death on or after 21 September 1999. If the home passes to a foreign resident, the tax office treats a gain event as happening just before death.
For the United Kingdom, the government website says a resident taxed in more than one country may claim relief, and may need a certificate of residence for the foreign tax office.
Taking credit for the tax paid abroad
A US taxpayer claims foreign income tax on Form 1116, and only the reduced treaty rate counts where a treaty applies. A Canadian resident claims the lesser of the foreign tax paid and the Canadian tax on that country's net income, on form T2209. One tax-preparer guide says Mexico's income tax is creditable for a US heir, and that property tax, transfer taxes and notary fees are not.
The widow's son meets this. A Canadian heir sells a home in Mexico. The Canadian side begins from the market value at death. The Mexican side may begin from something different. The credit then has two figures to match.
Where the sources differ
The Portuguese lower band is 12.5% in a PwC summary (tier B) and 13.25% in another guide (tier U). The French social levy is 17.2% for most sellers and 7.5% for sellers covered by social security elsewhere in the European Economic Area (PwC and Etudes fiscales internationales), so the total is 36.2% or 26.5%. Colombia's rate comes from law-firm guides (tier C). The Turkish and Thai figures come from guides and a news site (tier U), and the Thai table is from 2014.
A fair objection
You might say: my children will simply sell the house and bring the money home, so the details do not matter. They may. In Spain, proceeds over EUR 10,000 need a declaration to the central bank, and in Colombia a new exchange declaration goes through an authorised bank. Both are paperwork rather than a tax.
Doors you could open
You could write down, for each home, the sale tax where it stands and the starting cost in each child's country. You could ask whether your child would need to register in their own name before a sale, as Portugal asks.
If your family has sold an inherited home across a border, which office surprised you most? Share it here. Another family may be about to face the same two.
Figures are estimates for planning, based on public data. Date read: October 2026.
Sources
- Cornell LII on 26 USC 1014 (A)
- IRS Publication 551 and Form 1116 page (A)
- UK government property and relief pages (A)
- Canada Revenue Agency foreign tax credit page (A), taxtips.ca and Knowledge Bureau on death (C)
- ATO capital gains tax guide 2026 (A)
- PwC Worldwide Tax Summaries for Spain, Portugal, France and Greece (B)
- Agenzia delle Entrate ruling 129/2018 (A)
- Chambers Private Wealth 2026 for Mexico (B)
- Etudes fiscales internationales (B), tax-preparer guide for US citizens abroad (C)
- Siempre al Dia and Nexo Legal on Colombia (C)
- Forvis Mazars Thailand 2014 table (B), guides on a foreign-resident advice site for Spain, Portugal, Thailand and Turkey (U)
- Regfollower tax news (U)
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