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Cross-border estates, trusts, and gifts

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.

Canadian Tax

Are Gifts Taxable in Canada? No Gift Tax, With Two Catches

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.

Aug 24, 2026
Cross-Border

Bare trust reporting in Canada: the T3 rules

Canada 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.

Aug 27, 2026
Cross-Border

Canadian Trust with a US Beneficiary: Tax Traps

When a Canadian trust has a US beneficiary. When all parties are Canadian residents, these trusts work as designed. Covers treaty provisions, foreign tax.

Aug 21, 2026
Cross-Border

Cross-Border Estate and Inheritance Tax: What Happens When Assets and Heirs Are in Different Countries

The 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.

Sep 4, 2026
Cross-Border

Cross-Border Estate Planning for Canada and the US

Cross-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.

Sep 4, 2026
Cross-Border

Cross-Border Estate Planning: Freezes, Alter-Ego Trusts, and Bypass Trusts

Estate freezes, alter-ego trusts, and joint partner trusts are Canadian tools that collide with US estate tax, gift tax, and foreign trust rules.

Aug 21, 2026
Cross-Border

Cross-Border Gift Tax: How Canada and the US Tax Gifts Between Family Members in Different Countries

The US imposes a gift tax on the donor. Canada and the US handle gifts in fundamentally different ways. Canada has no gift tax.

Sep 4, 2026
Cross-Border

Cross-Border Inheritance: How Canada and the US Tax an Estate That Crosses the Border

Canada 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.

Aug 30, 2026
Cross-Border

Cross-border power of attorney for tax matters

If 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.

Aug 27, 2026
Cross-Border

Cross-Border Trusts Between Canada and the US: How Both Countries Tax Trust Income

A trust with connections to both Canada and the US faces dual taxation, complex reporting, and treaty provisions that often do not resolve the overlap.

Sep 4, 2026
Cross-Border

Death and Taxes Cross-Border: What Happens When Someone Dies with Assets in Both Countries

Canada taxes a deemed disposition at death. The US imposes estate tax on worldwide assets (or US-situs assets for non-residents).

Aug 30, 2026
Cross-Border

Deceased Parent's CRA/IRS Debt: What the Estate and the Kids Owe

The short answer: the estate pays, not the children, unless the children received assets from the estate before the tax debt was settled.

Aug 27, 2026
Cross-Border

Do I Need Two Wills? Cross-Border Estate Planning for Canada-US

If 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.

Aug 30, 2026
Cross-Border

Do I pay US tax on an inheritance or gift from my Canadian parent?

No, 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.

Aug 7, 2026
Canadian Tax

Does Canada Have an Estate Tax? What Applies at Death

No. 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.

Oct 24, 2026
Cross-Border

Executor liability in cross-border estates: Canada and US exposure

If you're the executor (or liquidator, in Quebec) of a cross-border estate, you've inherited a job with personal financial risk.

Aug 27, 2026
Canadian Tax

Family Trusts in Canada: What They Are, How They Work, and When They Make Sense

A 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.

Aug 24, 2026
Cross-Border

Form 706-NA: filing the US estate tax return for a Canadian who died owning US assets

A Canadian dies owning a Florida condo and a brokerage account holding US shares. Nine months later the IRS expects a return.

Aug 27, 2026
Cross-Border

I'm Canadian and Inheriting a US IRA or 401(k). How Is It Taxed?

Canada includes the full distribution in your income and gives you a foreign tax credit for the US withholding. Covers treaty provisions, foreign tax.

Aug 21, 2026
Canadian Tax

Inheritance Tax in Canada: There Isn't One, But Here's What Heirs Actually Pay

Canada has no inheritance tax, but the deceased's terminal return owes tax on deemed capital gains at death. Provinces charge probate fees.

Aug 24, 2026
Cross-Border

Joint tenancy (JTWROS) across the border: Canada and US tax traps

The 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.

Aug 27, 2026
Cross-Border

Life insurance across the border: Canada and US tax treatment

Life 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.

Aug 27, 2026
Cross-Border

My Spouse Is Canadian, Not a US Citizen. Do We Need a QDOT?

Without a QDOT, the marital deduction does not apply to a non-citizen spouse, and estate tax can hit at the first death.

Aug 21, 2026
Canadian Tax

Ontario Probate Fees: Avoidance Strategies, Multiple Wills, and the Cross-Border Layer

Ontario'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.

Aug 27, 2026
Canadian Tax

Post-Mortem Tax Planning: The 164(6) Pipeline for Private Corporation Shares

Then, when the estate redeems or sells those shares back to the corporation, subsection 84(2) converts the redemption proceeds into a deemed dividend.

Aug 27, 2026
Canadian Tax

Revocable vs Irrevocable Trust in Canada: Key Differences and Tax Treatment

Canadian 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.

Aug 24, 2026
Cross-Border

RRSP and RRIF on death: what a US-person beneficiary needs to know

A 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.

Aug 27, 2026
Cross-Border

Spousal trusts in Canada: cross-border planning for mixed-status couples

A Canadian spousal trust lets you transfer property to a trust for your spouse's benefit without triggering an immediate tax bill.

Aug 27, 2026
Canadian Tax

T1141 and T1142: Canadians and Foreign Trusts

T1142 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.

Oct 24, 2026
Cross-Border

Testamentary trusts after 2016: GRE and QDT rules in Canada

A 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,.

Aug 27, 2026
Cross-Border

US Estate Tax for Canadians Who Own US Property: What Happens When a Non-Citizen Dies Owning US Assets

The 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.

Sep 4, 2026
Cross-Border

US Estate Tax for Canadians: $60,000 Exemption vs Treaty

The $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.

Jul 30, 2026
Cross-Border

US Estate Tax for US Citizens Living in Canada

Yes. 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.

Oct 24, 2026
Cross-Border

US Estate Tax on a Canadian's Florida Vacation Rental

US 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.

Aug 27, 2026
Cross-Border

US person as trustee of a Canadian trust: the tax complications

A US citizen or green card holder as trustee can change a Canadian trust's US classification, trigger annual reporting. Covers treaty provisions, foreign.

Aug 27, 2026
Cross-Border

US Person Inheriting from a Canadian Estate: Tax Obligations on Both Sides of the Border

When 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.

Sep 4, 2026

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