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
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
Irish funds are not tax-free either
tax
An Irish fund loses 15% of its US dividends inside the fund — which may be about the same as you would lose holding the US fund directly.
The usual argument for Irish-domiciled funds is that they save you dividend tax. For a Thai resident that argument is materially weaker than it is usually stated. An Irish UCITS suffers 15% US withholding at fund level under the Ireland–US treaty. A Thai resident holding the US fund directly should, under the US–Thailand treaty, suffer 15% on portfolio dividends too — roughly the same leakage. MARKED AS INFERENCE, NOT VERIFIED FACT: the treaty rate reading, whether a given broker actually applies it (it may require a foreign tax identification number on the W-8BEN), and whether US Treasury-fund distributions qualify as interest-related dividends exempt from non-resident withholding were all beyond what could be confirmed. The reason to prefer Irish domicile is the estate-tax situs above, which is verified. The dividend argument is not the reason.
Not verified — Treaty rate and broker application inferred from the US–Thailand income treaty text; not confirmed against a primary ruling or a broker's own documentation.
Foreign income is taxed when you bring it in
tax
Money earned abroad from 2024 onward is taxable in Thailand in whatever year you remit it — the widely-reported 2025 relaxation was never actually enacted.
Departmental Instruction Por 161/2566, as amended by Por 162/2566, remains the law as at 25 July 2026. Foreign-sourced income earned from 1 January 2024 onward is assessable in Thailand when it is brought into the country, in any later year — not only in the year it was earned. Income earned before 2024 is grandfathered out entirely. The residence test that matters is applied in the year of remittance: money brought in during a year you spent fewer than 180 days in Thailand is not caught, even if it was earned in a resident year. The relaxation announced in 2025 and repeated widely since was verified negatively against the Revenue Department's own registers — Royal Decrees run to No. 805 of 4 March 2026 with none touching Section 41, and departmental instructions run to Por 164/2568 with none touching foreign-sourced income. Parliament was dissolved ahead of the February 2026 election and the proposal is shelved. Foreign tax credits exist only under a double tax agreement.
Verified 2026-07-25 · https://www.rd.go.th/fileadmin/user_upload/kormor/newlaw/di161.pdf