Inve Blog
Buying US Stocks from Australia: What You Keep
An A$20,000 worked example: 15% US withholding, FITO, FX fees, the 2027 CGT change and the estate tax treaty, plus what US firms said about Australia.
By Priya Rajan, Research Analyst·September 25, 2026
Reviewed & published by Inve Research Desk
This guide began with a mistake. The working brief said an Australian's US shares were exposed to American estate tax above US$60,000, because there is no estate tax treaty between the two countries. There is one. It dates from 1953, the IRS still lists Australia among its fifteen death-tax treaty partners, and it changes the arithmetic for almost everyone reading this. The US$60,000 figure is real, but it is a filing threshold, not the tax line, and Australian investment forums have been confusing the two for at least a decade.
How to buy US stocks from Australia takes two sentences: open an account with a broker that offers US markets, sign a W-8BEN, convert dollars, press buy. What you keep afterwards depends on four things the broker guides skip: what US companies say about Australia on their earnings calls, a worked example with every leak in it, the capital gains tax law Parliament passed on 25 June 2026, and that treaty.
The mechanics, briefly
US shares bought through an Australian broker are not held in CHESS, the ASX's settlement system; shares on the NYSE or Nasdaq sit with a custodian and you own the beneficial interest. A few US companies, Alcoa, ResMed and News Corp among them, also quote on the ASX as CHESS Depositary Interests, where "the product title is held by a depositary nominee company on your behalf," as ASIC's Moneysmart puts it. Either way the company is still American, which matters for dividends and estate tax.
The W-8BEN tells the paying agent you are an Australian resident, so dividends are withheld at the treaty rate of 15% instead of the statutory 30% (IRS Tax Treaty Table 1). It lasts to the last day of the third calendar year after signing, per the IRS instructions: a form signed in September 2026 runs to 31 December 2029. It applies to CDIs too; a Whirlpool poster in 2014 had US$11.25 taken from a US$37.50 ResMed dividend, which is 30%.
Currency conversion is where brokers differ most, and each quotes its fee on a different base. On 25 September 2026 CommSec's international account listed an FX fee of 0.55% per conversion. Stake quotes 55 basis points too, but its own example charges US$5.50 on an A$1,000 deposit at 70 US cents, which is US$0.55 per A$100 deposited: US$110 on A$20,000. Interactive Brokers listed 0.2 basis points of the trade value (0.22 with GST), minimum US$2. Those are published tariffs, not a broker recommendation.
A worked example: A$20,000, five years, every leak
Assumptions, so you can redo it. An Australian resident on a 32% marginal rate: the 30% income-tax bracket plus the 2% Medicare levy (ATO rates; before July 2024 that income-tax bracket was 32.5%, ignored here). On 24 September 2021 they convert A$20,000 at 0.7258 US dollars per Australian dollar (FRED DEXUSAL), pay a generic FX fee of 0.55% of the amount converted (a modelling assumption, not any one broker's tariff) and US$3 brokerage each way, and buy a US holding that tracks the S&P 500, which went from 4,455.48 to 7,650.50 by 18 September 2026. Dividends are assumed at 1.4% a year of the average holding value, kept in US dollars. They sell on 18 September 2026 and convert everything back at 0.7111. As a modelling shortcut, all dividends are translated at the five-year average rate of 0.6748; a real return translates each year's dividends in that income year, at the rate on the day or an ATO-accepted average. The cost base is the full A$20,000 outlay, treating the conversion fee and the purchase brokerage as incidental costs of acquisition (leave the conversion fee out and it would be A$19,890).
| Step | Amount |
|---|---|
| A$20,000 converted at 0.7258 | US$14,516.00 |
| FX fee in (0.55%) | −US$79.84 (A$110) |
| Invested after US$3 brokerage | US$14,433.16 |
| Value at sale (index up 71.71%) | US$24,783.17 |
| Dividends over five years (1.4% × US$19,608 × 5) | US$1,372.57 (A$2,034) |
| US withholding at 15% with a W-8BEN | −US$205.89 (A$305) |
| Australian tax on dividends at 32%, less the A$305 foreign income tax offset | −A$346 |
| Sale after US$3 brokerage, plus net dividends | US$25,946.86 |
| FX fee out (0.55%) | −US$142.71 (A$201) |
| Cash back in Australia | A$36,287.65 |
| Capital gain: A$34,847.65 proceeds − A$20,000.00 cost base | A$14,847.65 |
| CGT: 50% discount, then 32% | −A$2,376 |
| Kept after all tax | A$33,566 |
The investor ends with A$13,566 more than they started with, 67.8% on the original A$20,000. The frictions are the small print: A$311 of FX fees and A$8 of brokerage, together 1.6% of the starting amount. Tax took A$3,026, of which the US share was A$305, and that A$305 was not an extra cost, because the foreign income tax offset credited it against the Australian bill.
Now remove the W-8BEN. The US withholds 30%, another A$305. The ATO's offset guide is plain: only tax "in accordance with any tax treaty" counts, and the taxpayer "would need to seek a refund of the balance" from the foreign authority. The broker's withholding agent can sometimes reimburse over-withheld tax before its own filing deadline, under the IRS Form 1042-S instructions; otherwise it may take a US refund return, and on a small dividend stream that paperwork can cost more than the A$305 it recovers. The same guide notes that an offset up to A$1,000 needs no limit calculation, and that unused offset is neither refunded nor carried forward. Both tests apply one income year at a time.
The currency did something too. The index rose 71.7% in US dollars and 75.3% in Australian dollars, because the Aussie slipped from 0.7258 to 0.7111: over five years, a near wash. The path was not. The Aussie touched 0.5980 on 7 April 2025, and its climb from 0.6550 on 25 September 2025 to 0.7111 took 7.9% off US holdings in Australian-dollar terms in that year alone.
Think of the Aussie as a shock absorber: the ride matters more than the destination. Between 19 February and 8 April 2025 the S&P 500 fell 18.9%, but the Aussie fell from 0.6341 to 0.6015 over the same weeks, so an unhedged Australian holder lost 14.5%. It did the same in March 2020, when it hit 0.5859 on the 19th. When the world is frightened the Aussie usually falls, and that is when US shares fall. Hedging removes the absorber along with the drift; whether that trade is worth it depends on which you fear more.
For the tax that follows, check with a qualified tax adviser in Australia. The example is arithmetic, not advice on your return.
What changes on 1 July 2027
The 50% CGT discount in that table has an end date. The Treasury Laws Amendment (Tax Reform No. 1) Bill 2026 passed both Houses on 25 June 2026 and received assent the next day as Act No. 49 of 2026. It replaces the discount for individuals, trusts and partnerships "with cost base indexation and a 30 per cent minimum tax rate on capital gains accruing on and after 1 July 2027", in the Parliament's summary. For shares you already own, the Act treats a resident individual as selling them just before, and reacquiring them on, 1 July 2027 (section 112-155). The gain up to that point is deferred until you actually sell and keeps the 50% discount; the gain after it is indexed. The split uses market value just before 1 July 2027, unless you choose an apportioning method that the Minister may set by legislative instrument (section 112-185). The Act leaves the detail of that optional method to the instrument; everything else described here is already law.
For US shares the change bites in two places. Indexation lifts the cost base by inflation, so only the real gain is taxed, but it is taxed at your full rate. Run the same five years as if they had started in July 2027. Australian CPI rose 23.0% between the September quarter of 2021 (83.17) and the June quarter of 2026 (102.31), on the ABS index. Indexed, the A$20,000 cost base becomes A$24,603 and the taxable gain A$10,245. At 32% that is A$3,278 of tax, against A$2,376 under the discount. For this investor, the new rules cost A$903, about 6% of the gain. (The statutory indexation factor is set quarter by quarter and rounded, so treat these as approximations.)
The second bite is sharper, and the mechanism is already in the Act. Division 119 applies to an individual who is an Australian resident at any time in the year (section 119-10). Take 30% of your post-July-2027 gains (section 119-5), then subtract the income tax those gains actually add to your bill, worked out before offsets and before the Medicare levy. If anything is left, it is a "minimum tax gap amount" and you pay it as extra tax. In plain terms, the gain is taxed at no less than 30%. That lands hardest on people who hold US shares for decades and sell after they stop work. Selling the same holding in a year when the whole gain sits in the 15% bracket would cost A$1,114 under the discount, and A$3,074 under the 30% floor. Both figures exclude the Medicare levy, which still applies to taxable income even though the floor calculation leaves it out; at the full 2% they become about A$1,262 and A$3,278, and low-income levy reductions can lower them. Section 119-15 switches the floor off for anyone who receives, at any time in the year, a listed payment: the Age Pension, JobSeeker, the disability support pension, carer payment, family tax benefit, parental leave pay and others. The Bills Digest adds that complying super funds, companies and foreign residents generally sit outside the new regime. Treat the dollar figures as illustration: a law that starts in 2027, applied to five years that already happened.
US estate tax: the number that frightens people is the wrong one
A non-resident who is not a US citizen gets a unified credit of US$13,000, which covers about US$60,000 of US assets; above that, the executor files Form 706-NA. Shares in a US company count as US property "irrespective of the location of the certificates", in the words of the Treasury regulation. That includes shares held through an Australian broker's custodian, and on its face US companies held as CDIs. Without a treaty, US$300,000 of US shares would face US$87,800 of tentative tax, less the US$13,000 credit: US$74,800, a quarter of the holding.
Australia has a treaty. The Form 706-NA instructions list Australia among the treaties that trigger the pro-rata credit in section 2102(b)(3)(A) of the Internal Revenue Code: the estate gets the credit a US citizen would get, scaled by US assets over worldwide assets. For deaths in 2026 the US basic exclusion is US$15,000,000, which carries a credit of US$5,945,800. With US$300,000 in US shares, the estate owes nothing unless the worldwide estate exceeds roughly US$20.3 million.
So the tax is rarely the problem. The paperwork is. Above US$60,000 of US assets the estate still files 706-NA to claim the treaty, and a US custodian can require an IRS transfer certificate before releasing the shares. For a filing estate, the IRS issues that certificate only once it is satisfied any tax has been "fully discharged or provided for", and it publishes no timetable for that route. Its one published estimate, "12 to 18 months", is for smaller estates below the filing threshold that apply by affidavit instead. Any US estate tax that is paid does not come back as an Australian credit either: the ATO lists inheritance taxes among foreign taxes that do not count towards the offset. A Whirlpool poster in 2016 was told by an accountant that a tax credit should follow. It would not.
How Inve helps an Australian investor research a US company
The six companies above came from Inve's reading of US earnings calls. Every covered company has a stock page, reached from the A–Z of US stocks, with its calls distilled: each piece of guidance with the target, period, speaker and verbatim quote, and the analyst Q&A graded for whether management answered directly, partially or not at all. Alcoa's "timing could extend" and CoStar's "late 2027" surfaced that way: the same line, read across consecutive calls. The method is in how to read an earnings call transcript.
The Guidance Tracker keeps those commitments in one ledger — the original wording, the quarter it was made, the period it was due, and what happened to it — so a date that slides from 2026 to 2027 does not depend on your memory. You can do it by hand, as tracking management guidance across quarters explains; almost nobody keeps that file for ten holdings, every quarter. The US earnings calendar shows when the next calls fall, which for an Australian usually means early morning. The earnings-call briefs and company pages are public, no account needed; the full Guidance Tracker history is part of US Pro, which gives each account one free month.
Where this can mislead you
The call data are Inve's summaries of transcripts to 10 September 2026, not the transcripts, and a count depends on the summary using the word "Australia": a company that says "ANZ" or names a city is missed. The six examples were picked for being vivid and checkable, not representative.
The worked example uses an index as a stand-in, a flat marginal rate, an assumed dividend yield and one average exchange rate for dividends, and it ignores the foreign-currency gain and loss rules that can apply to US dollar cash held between trades. The 2027 comparison applies a law that has not started to five years that already happened. The estate section describes rules; the treaty position still has to be claimed, correctly, by your executor.
The owner's question
An Australian who buys US shares is making three bets at once: on American companies, against the Australian dollar, and on the tax treatment of a gain they may not realise for twenty years. The first bet is the one everyone researches. The other two just changed. Parliament rewrote the third in June, and the Aussie has risen 19% against the US dollar since its April 2025 low. What does your plan look like if you sell in a year when you earn nothing but the gain?
Frequently asked questions
You can buy without one, but your dividends will be withheld at 30% instead of the treaty rate of 15%, and the ATO only credits the 15%. The form lasts until 31 December of the third year after you sign it, and it also applies to US companies you hold as CDIs on the ASX.
Rarely as a tax, because the 1953 US–Australia treaty gives the estate a share of the US$15 million exclusion (2026) in proportion to its US assets. It is a real administrative burden: above US$60,000 of US assets the executor files Form 706-NA, and a custodian can hold the shares until the IRS issues a transfer certificate, for which the IRS publishes no timetable. Even for smaller estates using the affidavit route, the IRS estimate is 12 to 18 months.
Yes. It covers CGT assets held by individuals, trusts and partnerships, including shares. For a resident individual who has held the shares at least 12 months, the part of the gain that accrued before 1 July 2027 keeps the 50% discount. The later part is indexed for inflation and, under Division 119, taxed at no less than 30%, unless you received a listed payment such as the Age Pension during that income year.
Over 24 September 2021 to 18 September 2026 the S&P 500 rose 71.7% in US dollars and 75.3% in Australian dollars. In the year from 25 September 2025 the rising Aussie took 7.9% off US holdings in Australian-dollar terms.
Partly. The US company pages and earnings-call briefs are public and free. The full Guidance Tracker history, the Ambition Index and the other US Pro tools come with one free month per account, then a paid plan.
Read what US management actually said
Guidance with the speaker and the verbatim quote, the analyst Q&A graded, and a ledger of what happened to each commitment across 899 US companies. The call briefs are free to read.
Browse US companiesInve is a research and analysis platform, not an investment adviser. Nothing here is a recommendation to buy or sell any security. Do your own research or consult a qualified financial professional.