US estate tax for Canadians, the deemed disposition at death, inheritances and gifts across the border, Canadian trusts with US beneficiaries, executors, wills, and joint ownership.
36 guides, each written by a CPA licensed in the US and Canada.
Canada has no gift tax, and cash gifts aren't taxed to giver or recipient. Gifting stocks or real estate triggers capital gains for the giver, and US recipients may need Form 3520.
Cross-BorderCanada now requires T3 filings for bare trusts worth over $50,000. Here's who has to file, what the penalties are, and how US persons get caught twice.
Cross-BorderWhen a Canadian trust has a US beneficiary. When all parties are Canadian residents, these trusts work as designed. Covers treaty provisions, foreign tax.
Cross-BorderThe US imposes estate tax on worldwide assets of US persons and on US-situs assets of non-residents. Canada taxes gains at death through deemed.
Cross-BorderCross-border estate planning starts with status: who's a US citizen, who lives where, and what sits in which country. Then line up the treaty credits, beneficiaries and deadlines.
Cross-BorderEstate freezes, alter-ego trusts, and joint partner trusts are Canadian tools that collide with US estate tax, gift tax, and foreign trust rules.
Cross-BorderThe US imposes a gift tax on the donor. Canada and the US handle gifts in fundamentally different ways. Canada has no gift tax.
Cross-BorderCanada taxes the gain via a deemed sale at death; the US taxes estate value over $15,000,000 in 2026, and a Canadian's US assets over $60,000 before the treaty credit.
Cross-BorderIf you live in one country and have tax obligations in the other, one power of attorney rarely covers everything. Here's what the IRS and the CRA each need on file.
Cross-BorderA trust with connections to both Canada and the US faces dual taxation, complex reporting, and treaty provisions that often do not resolve the overlap.
Cross-BorderCanada taxes a deemed disposition at death. The US imposes estate tax on worldwide assets (or US-situs assets for non-residents).
Cross-BorderThe short answer: the estate pays, not the children, unless the children received assets from the estate before the tax debt was settled.
Cross-BorderIf you own property in both countries, one will can be valid in both, but two wills, each limited to one country's assets and not revoking the other, usually work better.
Cross-BorderNo, it's not taxable income. But once a gift or inheritance from a Canadian parent tops $100,000 in a year, Form 3520 is required.
Canadian TaxNo. Canada has no estate tax, but death triggers income tax on the deceased's final return through the deemed disposition and RRSP or RRIF inclusion, plus provincial probate fees.
Cross-BorderIf you're the executor (or liquidator, in Quebec) of a cross-border estate, you've inherited a job with personal financial risk.
Canadian TaxA family trust in Canada is a type of personal (inter vivos) trust created during the settlor's lifetime, typically to hold assets for the benefit.
Cross-BorderA Canadian dies owning a Florida condo and a brokerage account holding US shares. Nine months later the IRS expects a return.
Cross-BorderCanada includes the full distribution in your income and gives you a foreign tax credit for the US withholding. Covers treaty provisions, foreign tax.
Canadian TaxCanada has no inheritance tax, but the deceased's terminal return owes tax on deemed capital gains at death. Provinces charge probate fees.
Cross-BorderThe tax consequences aren't simple at all, and they get worse when one of those names belongs to a US citizen or green card holder.
Cross-BorderLife insurance is one of those things that works beautifully in one country and then falls apart when you add the other country's tax rules.
Cross-BorderWithout a QDOT, the marital deduction does not apply to a non-citizen spouse, and estate tax can hit at the first death.
Canadian TaxOntario's estate administration tax charges 1.5% on every dollar of estate value above $50,000. On a $2 million estate. Covers key rules, filing.
Canadian TaxThen, when the estate redeems or sells those shares back to the corporation, subsection 84(2) converts the redemption proceeds into a deemed dividend.
Canadian TaxCanadian trust law and tax law treat revocable and irrevocable trusts very differently, and the distinction matters more here than in the US. In the US.
Cross-BorderA Canadian RRSP or RRIF is generally taxed in full on the holder's final return unless it rolls to a spouse. Here's how Canada and the US treat a US-person beneficiary.
Cross-BorderA Canadian spousal trust lets you transfer property to a trust for your spouse's benefit without triggering an immediate tax bill.
Canadian TaxT1142 reports what you got from a non-resident trust; T1141 reports what you put in. Who files each, the estate exception, the April 30 due date and the penalties.
Cross-BorderA testamentary trust is any trust that arises on (and because of) a person's death, typically created by a will. Covers key rules, filing requirements,.
Cross-BorderThe US imposes estate tax on US-situs assets of non-resident aliens. Canadians who own US property get a prorated unified credit under Article XXIX-B.
Cross-BorderThe $60,000 is only the default. A Canadian resident's estate can trade the $13,000 credit behind it for a prorated share of the 2026 $15 million exclusion on Form 706-NA.
Cross-BorderYes. A US citizen in Canada owes US estate tax on a worldwide estate above the 2026 $15 million exclusion, Canada taxes the deemed gains, and treaty credits limit the overlap.
Cross-BorderUS real property is a US-situs asset for estate tax purposes, and the $60,000 NRA exemption covers almost nothing. Covers treaty provisions, foreign tax.
Cross-BorderA US citizen or green card holder as trustee can change a Canadian trust's US classification, trigger annual reporting. Covers treaty provisions, foreign.
Cross-BorderWhen a US person inherits from a Canadian estate, the estate pays Canada's tax on deemed gains. The US heir usually owes no US tax but may need Form 3520 and an FBAR.