No. I'm saying that if the decedent of an estate is a nonresident alien and has assets that are situated in the U.S. when he or she died then the estate only gets a unified credit of $13,000 to cover those U.S. assets in his/her estate. IRC § 2102(b)(1). That credit then effectively covers the transfer of $60,000 of assets (as opposed to the unified credit that U.S. citizens get that effectively covers the transfers of $11,580,000 of assets). In short, the estate of a nonresident alien may only pass up to $60,000 of assets situated in the U.S. without paying any estate tax. If the value of estate assets situated in the U.S. exceeds $60,000 then there will be estate tax for the estate to pay.
I should note, which I did not make clear earlier, that the nonresident alien does not get the benefit of the unified credit towards gift tax for gifts made during his/her lifetime. For the nonresident alien, the unified credit only applies to the estate tax, not gift tax.
The nonresident alien does get the benefit of the annual gift tax exclusion that citizens and residents get, however, and which now stands at $15,000. Putting this all together then, we have the following results for the nonresident alien:
For gifts made during the nonresident alien's lifetime, he or she may give up to $15,000 each year of property situated in the U.S. to as many persons as he or she wants without any gift tax consequence. But if he or gives gifts of property situated in the U.S. to any one person during the year that total more than $15,000 then the nonresident donor will pay gift tax on the amount of the gifts that exceeds $15,000. So, for example if Amy, a nonresident alien, in 2020 makes gifts totaling $37,000 of property situated in the U.S. to Bart (who is not her spouse), she will will have made taxble gifts to Bart in the amount of $22,000. Because Amy does not get any unified credit for gift tax, she will have to actually pay gift tax on the $22,000 of taxable gifts she made to Bart. Note that this is true regardless of whether Bart is a citizen/resident of the U.S. or whether Bart is a nonresident alien.
After Amy dies, her taxable estate for federal estate tax purposes will be determined by the value of the property she had situated in the U.S. at the time she died. In computing the tax, the estate will get a $13,000 unified credit, which allows the first $60,000 of assets to pass free of estate tax. So, suppose that Amy, who was still a nonresident alien when she died in 2021, had $110,000 of assets situated in the U.S. Because the unified credit effectively allows the first $60,000 of the estate to pass tax free, the estate will end up paying estate tax on $50,000 of estate assets. Again, it doesn't matter whether the beneficiaries receiving the assets are citizens/residents of the U.S. or nonresident aliens unless the beneficiary was the spouse of the decedent at the time of death.
Thus, the nonresident alien donor may pass only a relatively very small amount of assets situated in the U.S. tax free compared to the U.S. citizen/resident donor. But the nonresident alien in many cases can avoid or at least reduce this problem by ensuring as much as possible that the gifts made, whether during life or at death, are not of property situated in the U.S.
Note that the citizenship/residency of the donee does not matter for federal estate and gift tax except if the donee is the spouse of the donor. So, to circle back to something that Original seemed to be asking that I didn't directly address before, if a nonresident alien gives a gift to another person (other than his spouse) the same rules apply whether the person receiving the gift (the donee) is a citizen, resident, or nonresident alien. So, as I pointed out with my examples above, it is quite possible for a gift made by a donor who is a nonresident alien and that is made to a nonresident alien donee to still end up being subject to estate or gift tax. The key is whether the property given is property situated in the U.S.