RetireJapan

Goodness, thank you again for all this detailed information. Much appreciated! I should have mentioned earlier, my wife became a US citizen about 15 years ago. When she did that she was forced to give up her Japanese citizenship. When we returned to Japan, she later got her Japanese citizenship back. Kind of a long story. Japan seems to care more than the U.S. about having two passports but that is what she has now. So it seems estate planning is much easier and much less expensive if the U.S. is our domicile.

Under the 1954 US Japan Estate Inheritance and Gift Tax Convention (https://www.mofa.go.jp/mofaj/gaiko/trea ... 3)-256.pdf), your wife is treated no differently than a US citizen spouse.
A good article on the matter is available here (google translate does a fair job with it)...https://kslaw.jp/column/detail/4597/
Probably best to ignore all of the 'general' advice regarding non-resident alien spouses found in articles online.
The non-resident alien rules do not apply due to the treaty.
If you decide to seek professional advice (not a bad idea), I would consider seeking someone with US-Japan expertise.

10-7 wrote: ↑Mon Dec 12, 2022 1:16 am Under the 1954 US Japan Estate Inheritance and Gift Tax Convention (https://www.mofa.go.jp/mofaj/gaiko/trea ... 3)-256.pdf), ...

A BIG thank you for this post! (that's old, and I'll be looking thru later, but still...!)

For example, I had read elsewhere (not on RJ) that:

...the Japan-US inheritance tax treaty prohibits Japanese residents from being treated worse than US residents for estate tax purposes, so this punitive taxation of US assets inherited by non-residents doesn't apply to Japanese residents.

Hopefully, the link you provided will substantiate that.