Same coast. Different rules at home.
The Florida side of a purchase is much the same for every international buyer. What differs is your side: the passport you travel on, whether your country has a tax treaty with the United States, and what your own tax authority expects you to report. This page is a map so you know what to ask; the professionals in our directory apply it to your situation.
Three things that are true wherever you live
- Buying doesn't change your status
- Owning a home in the United States doesn't by itself give you a right to live here beyond your normal visitor stays. Most owners simply visit, and that works well. If you're thinking about living here longer, an immigration attorney can explain your options; we can introduce you to one.
- Your passport decides entry
What is an ESTA? The Electronic System for Travel Authorization is a short online application that citizens of about 40 countries in the U.S. Visa Waiver Program complete before flying to the United States. It's approved in minutes or days, is usually valid for two years, and lets you visit for up to 90 days at a time without a visa.
Canadian citizens don't need an ESTA or a visa and are usually admitted for up to six months. Citizens of other countries apply for a visitor visa at a U.S. consulate. What counts is the passport you travel on, not where you live. The U.S. State Department's Visa Waiver page is the official list. Your entry allowance is separate from the tax day count.
- How you hold it
- Personally, through a trust or through a company. The choice affects U.S. estate tax, your reporting at home and what happens when you sell, so it's worth deciding before you sign a contract. We can introduce you to subject-matter experts who set this up every day.
Entry and the estate tax treaty, by country
What the treaty column means. When someone who lives outside the U.S. dies owning U.S. property, U.S. estate tax can apply. Without a treaty, only the first $60,000 of U.S. property is exempt. A treaty can raise that exemption or decide which country taxes the estate, which often reduces the U.S. tax a great deal. For countries marked "No", planning how you hold the property matters more, and it's very manageable with good advice.
Both lists change over time. This table was checked on 1 October 2026; confirm against the official sources below before relying on it.
| Country of citizenship / residence | Visa Waiver (ESTA) | U.S. estate tax treaty |
|---|---|---|
| Canada | Visa-exempt | Yes, via the income tax treaty |
| United Kingdom | Yes | Yes |
| Ireland | Yes | Yes |
| France | Yes | Yes |
| Monaco | Yes | No |
| Italy | Yes | Yes |
| Greece | Yes | Yes |
| Spain | Yes | No |
| Portugal | Yes | No |
| Malta | Yes | No |
| Switzerland | Yes | Yes |
| Germany · Austria · Netherlands | Yes | Yes |
| Belgium · Luxembourg | Yes | No |
| Denmark · Norway · Finland | Yes | Yes |
| Sweden | Yes | No |
| Israel | Yes | No |
| Qatar | Yes | No |
| United Arab Emirates · Saudi Arabia | Visitor visa | No |
| Mexico · Brazil · Colombia · Argentina | Visitor visa | No |
| Chile | Yes | No |
| Bahamas · Cayman · Bermuda · BVI | Depends on passport | No |
| Australia | Yes | Yes |
| New Zealand · Singapore · South Korea | Yes | No |
| Japan | Yes | Yes |
| South Africa | Visitor visa | Yes |
Sources: U.S. State Department — Visa Waiver Program; IRS — U.S. tax treaties A to Z. Both lists change; this table was checked 1 October 2026.
Every province and territory, one border
Canadians are the largest group of foreign buyers on this coast. The Canada–U.S. tax treaty gives Canadian residents a pro-rated share of the full U.S. estate tax exemption, which covers most families at ordinary price points. Your Canadian return taxes an eventual gain, with credit for U.S. tax paid, and a property you rent out can count as foreign property for the CRA's T1135 report. We work in French as readily as in English.
Two tax returns
Quebec residents file a provincial return with Revenu Québec in addition to the federal return with the CRA, and Quebec's foreign tax credit rules differ in places from the federal ones. For RAMQ health coverage, you generally need to be in Quebec at least 183 days in a calendar year.
One return, OHIP rules to watch
Ontario residents file one federal return that includes provincial tax. To keep OHIP coverage you generally need to be in Ontario at least 153 days in any 12-month period, which allows up to about seven months away.
One return, check AHCIP first
Alberta residents file one federal return. Published guidance on how long you can be away and keep AHCIP coverage differs between sources, so confirm your plans with Alberta Health before you leave.
| Province or territory | Income tax filed with | Health plan | Snowbird note (confirm with your plan) |
|---|---|---|---|
| Quebec | CRA and Revenu Québec | RAMQ | Generally 183 days present per calendar year |
| Ontario | CRA | OHIP | Generally 153 days present in any 12 months |
| British Columbia | CRA | MSP | About 6 months present; up to 7 months away for vacation with notice |
| Alberta | CRA | AHCIP | Sources differ; confirm with Alberta Health |
| Manitoba | CRA | Manitoba Health | Generally 183 days present per calendar year |
| Saskatchewan | CRA | Saskatchewan Health | Confirm with eHealth Saskatchewan |
| New Brunswick | CRA | Medicare | Generally up to 212 days away in any 12 months |
| Nova Scotia | CRA | MSI | Confirm with MSI |
| Prince Edward Island | CRA | Health PEI | Confirm with Health PEI |
| Newfoundland and Labrador | CRA | MCP | Confirm with MCP |
| Yukon · Northwest Territories · Nunavut | CRA | Territorial plan | Confirm with your territorial plan |
Health-plan rules change and some allow longer absences with prior approval. Always confirm with your provincial or territorial plan before you travel.
Provincial plans pay only a small part of U.S. medical costs, so most Canadians wintering in Florida add travel medical insurance, which usually requires that your provincial coverage stays valid. Owners who spend longer here, or who don't qualify for provincial coverage, can look at international private medical insurance or U.S. plans available to non-residents. We can introduce you to insurance advisors who specialise in cross-border coverage.
Nova Horizons does not carry on real estate brokerage in Quebec, anywhere else in Canada or in Florida, and is not licensed by the OACIQ or any real estate regulator.
Treaty in place, rules recently changed
England, Scotland, Wales, Northern Ireland
The U.S.–UK estate and gift tax treaty usually decides which country taxes what on death. UK residents are taxed at home on worldwide gains with credit for U.S. tax. The UK replaced the non-domicile regime with a residence-based system in April 2025, which changes the picture for many internationally mobile families; confirm your position before you buy.
Treaty in place
Ireland has an estate tax treaty with the United States. Irish residents report foreign property and pay Irish capital gains tax on disposal with credit for U.S. tax.
Not covered by the UK treaty
The Crown Dependencies have their own tax systems and aren't covered by the U.S.–UK estate treaty. For a resident who owns Florida property in their own name, that means only the first $60,000 of the property's value is exempt from U.S. estate tax, so it's worth planning how to hold it. Most residents travel on British passports and use an ESTA.
One language, three tax positions
Treaty in place
France has an estate and gift tax treaty with the United States. French tax residents include worldwide real estate in the base of the IFI real estate wealth tax, and report foreign accounts and holdings annually.
No treaty
Monaco has no estate tax treaty with the United States. Residents who are not French nationals generally pay no personal income tax in Monaco, which makes U.S. estate tax the main exposure to plan for. French nationals living in Monaco remain within French tax rules under the 1963 convention.
French departments
The overseas departments are part of France, and their residents are French tax residents with some local adjustments. The French treaty and French reporting rules apply. Saint-Barthélemy and Saint-Martin are overseas collectivities with their own tax regimes; ask your adviser which applies.
Where the treaty question decides the structure
Treaty in place
Italy has a long-standing estate tax treaty with the United States. Italian residents pay IVIE on real estate held abroad and declare it annually; U.S. property tax is generally creditable against it.
Treaty in place
Greece has an estate tax treaty with the United States. Greek residents are taxed at home on worldwide income with credit for foreign tax paid.
No treaty
Neither has a U.S. estate tax treaty, so for a resident who owns a Florida condo in their own name only the first $60,000 is exempt from U.S. estate tax. Good planning on how to hold it solves most of this. Spanish residents also declare foreign assets on Modelo 720 and are subject to a wealth tax on worldwide assets, with regional reliefs.
Follow the country
The islands follow their country's rules: Corsica is France, Sardinia is Italy, the Balearics are Spain. Malta and Cyprus have no U.S. estate tax treaty. Entry depends on the passport; Maltese citizens use ESTA.
Mostly treaty countries, with exceptions
Treaty in place
Switzerland has an estate tax treaty with the United States. Foreign real estate is generally exempt from Swiss income and wealth tax but counts toward the rate applied to everything else, so it still matters at home.
Treaties in place
Each has an estate tax treaty with the United States. All three tax their residents on worldwide income under their income tax treaties, with relief for U.S. tax on U.S. property.
No estate treaty
Neither has a U.S. estate tax treaty; plan the holding structure before buying. Both have income tax treaties that govern the rental and sale side.
Treaty, except Sweden
Denmark, Norway and Finland have estate tax treaties with the United States. Sweden's was terminated, so Swedish residents plan for U.S. estate tax directly.
Caribbean and Atlantic neighbours
The Bahamas, the Cayman Islands, Bermuda, the British Virgin Islands, the Turks and Caicos and their neighbours sit an hour or two from this coast, and many of their residents keep a second home here. None has a U.S. estate tax treaty, and most have no income or estate tax of their own, so there's no home-country credit to offset U.S. tax. Entry depends entirely on the passport you hold: British citizens use ESTA, others need a visa or a specific exemption. Holding structure matters more here than almost anywhere.
No treaty, so structure first
Visa Waiver since 2023
Israel has no estate tax of its own and no estate tax treaty with the United States, so U.S. estate tax exposure is planned for directly. A large and growing share of the Miami-Dade and Boca Raton market.
No treaty
Qatar joined the Visa Waiver Program in 2024; Emirati and Saudi citizens apply for a visitor visa. No home income tax means no credit to offset, and no treaty means U.S. estate tax applies in full above $60,000. Purchases are almost always structured, and entity purchases without financing trigger a federal ownership report at closing.
The other half of Miami's foreign buyers
Buyers from Mexico, Colombia, Brazil, Argentina, Chile, Peru and Panama are a large share of Miami-Dade's international market. None of these countries has a U.S. estate tax treaty, so structure is the first conversation. Chile is in the Visa Waiver Program; most others require a visitor visa. Several tax their residents on worldwide income and require annual declarations of foreign assets. We work in Spanish as well as English, French, Italian and Hebrew; for Portuguese-language transactions we'll introduce a colleague who works in your language.
Allies across the Pacific
Treaties in place
Both have U.S. estate tax treaties. Australia has no estate tax of its own; Japan taxes residents' worldwide estates and gives credit for U.S. tax.
No estate treaty
All are in the Visa Waiver Program; none has a U.S. estate tax treaty. Plan the holding structure before buying.
This page describes rules in general terms so you know what to ask. It doesn't apply them to you, and it isn't tax, legal or immigration advice in the United States or in your country. If your country isn't listed, the three rules at the top still apply, and we'd still like to hear from you.
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