USA "trust" estate tax rate is 33%
The original question was about
estate tax, which refers to a tax on the
value of assets when a person
dies.
I think you are confusing estate tax with
income tax.
The estate tax, or death tax as it is often called, is indeed applicable to a person who is neither a US citizen nor a US resident, if they own assets located in the USA at the time of their death. And the definition of "assets located in the USA" includes common stock of US-based corporations, even if the stock is held in a brokerage account that is
not based in the USA.
Some countries have a death tax
treaty with the USA, and citizens of those countries may not have to pay US estate tax when they die.
Income tax is completely different. If a person is not a US citizen or resident, and their assets are held in a brokerage account that is
not based in the USA, then in most cases, US income tax is not applicable.
A trust and an estate are two different things. Both entities use Form 1041, and this may be what is confusing you. In some cases an estate may have to pay
income tax, and that tax is reported on Form 1041. But the
estate tax, or death tax, is reported on Form 706.
BMK