The frictions are the parts that cost money or attention regardless of whether the argument is right: tax, transfer limits, deadlines, structure. For most people most of the time they matter more than the market reading does.
U.S. estate filing threshold — US$60,000
legal
For a nonresident who is not a U.S. citizen, an estate generally has to file Form 706-NA when aggregate U.S.-situated assets and the specified adjusted gifts exceed US$60,000; filing does not automatically mean tax is due.
For a deceased nonresident who is not a U.S. citizen, the Form 706-NA filing test aggregates U.S.-situated assets with the gift-tax specific exemption and adjusted taxable gifts; the published threshold is US$60,000. Crossing a filing threshold does not by itself establish estate tax due. The instructions say stock of corporations organised under U.S. law is U.S.-situated and other corporate stock is generally outside U.S. situs. VOO and VT are therefore U.S.-situated holdings, while shares in an Irish-domiciled UCITS company are generally not. Thailand does not appear on the IRS estate-and-gift treaty list. For a Thai-domiciled investor, the Irish structure can remove this particular holding from the U.S.-situated total, but it cannot remove other U.S. assets or replace estate advice.
Verified 2026-07-25 · https://www.irs.gov/instructions/i706na
Depositary receipts — 10%, and a trap if you claim relief
tax
A DR's dividend is taxed 10% in Thailand, on top of whatever the foreign country already took — and claiming that foreign tax back forfeits the Thai exemption.
Royal Decree No. 775, effective 16 August 2023, sets a 10% withholding on the 'money equivalent to dividends' paid on a depositary receipt, and exempts that amount from personal income tax provided the withholding was at most 10% AND the holder does not claim a refund or a tax credit for it. That last condition is the trap: a holder who tries to reclaim foreign tax withheld on the underlying share loses the Thai exemption on the whole amount. The 10% stacks on top of foreign withholding at source. No source quantifies the combined leakage, so none is stated here.
Verified 2026-07-25 · https://www.set.or.th/en/market/product/dr/overview
You spend baht
structural
A foreign asset can rise in its own currency and still lose you money in baht.
Every unhedged foreign holding is two bets: the asset and the exchange rate. Over a decade the exchange rate mostly washes out; over the two or three years in which someone actually needs the money it frequently does not. This is not an argument against foreign assets — it is an argument for keeping the money you will spend within five years in the currency you will spend it in.
Verified 2026-07-25 · https://www.bot.or.th/en/statistics/exchange-rate.html