Short answer: Hong Kong has no gift or estate tax; Taiwan has both; and US residents share one lifetime exemption across gifts and estates. When family members live in all three places, or assets are spread across them, succession needs planning as a whole.
The three compared (2026)
| Hong Kong | Taiwan | United States | |
|---|---|---|---|
| Gift tax | None | NT$2.44 million per donor per year, then 10–20% | USD 19,000 per recipient a year; USD 15 million lifetime for residents |
| Estate tax | None (abolished in 2006) | NT$13.33 million exemption, then 10–20% | Shares the USD 15 million lifetime exemption, then up to 40% |
| Basis | Not applicable | Nationals ordinarily resident in Taiwan on worldwide assets; others on Taiwan assets | Residents on worldwide assets; non-residents on US assets |
Taiwan estate tax rates
| Net estate | Rate |
|---|---|
| Up to NT$56.21 million | 10% |
| NT$56.21–112.42 million | 15% |
| Over NT$112.42 million | 20% |
Common family situations
- Parents stay in Taiwan, children move to the US: gifts mainly involve Taiwan gift tax; the children generally report receipts under US rules.
- The whole family moves to the US: with green cards you are generally US residents, so worldwide assets may fall under US estate tax, with the USD 15 million exemption.
- Hong Kong families: Hong Kong itself has no gift or estate tax, but your new country may — plan around your new status.
- Non-residents holding US assets: for example US property — the non-resident estate tax exemption is very low, so plan ownership early.
Our advice
Start succession planning before emigrating: settle where family members will live and their tax status, then decide gift timing, holding structures and insurance. GI Capital can help coordinate family asset planning.
General information only, not tax or legal advice. Read more: Taiwan gift tax explained and US gift tax before and after the green card. As of October 2026.