The IRS requires a mark to market the year you renunciate, assuming you meet the income and net worth requirements. (Or should I say fail these requirements?)
If assets are sold, money and residency moved offshore, have you escaped the estate tax? Is the gain subject to capital gain rates per normal rules?
If assets are not sold, but residency moved offshore, are only the assets remaining in the US subject to estate tax?
If you are talking about non-citizens and non-residents, the answer is yes. If you are talking about US citizens who give up their citizenship and residence to avoid US taxes, the answer is no, at least not for the ten years after they leave the US and give up their citizenship.
Assuming you are talking about those who were never US citizens, and who have given up residence, the answer is yes.
On the other hand deductions from the estate tax for non-citizen non-residence are based on a proportion of world-wide deductions to world-wide assets. If worldwide assets and deductions are not disclosed, no deductions are allowed.
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