Estate tax; resident alien decedents

QUESTION: XXX, a Korean citizen, was a permanent resident of the Philippines. He died in Seoul, Korea.

He left 100,000 shares in Jollibee Food Corporation, two (2) condominium units in Makati City and a house and lot in Tokyo, Japan. Should all these properties be included in the estate tax return?

ANSWER: Yes, all of these properties should be included in the estate tax return.

Properties of resident alien decedents are subject to estate tax wherever they are situated. This is according to the National Internal Revenue Code.

XXX is a resident alien decedent. The house and lot in Tokyo, Japan shall be included despite being outside the Philippines.