If you have a “single-purpose” corporation for U.S. estate tax planning, this may be a good time to explore an alternative way of holding U.S. real estate.
In general, the payment of amounts for services rendered triggers some form of tax reporting and often, an obligation on the payer to withhold and remit amounts on account of tax. Payments made to trustees and executors are no different.
As the thermometer continues to hover around the zero degree mark, many of us who live north of the 49th parallel begin to think about heading south to take up residence in one of the many sunnier climes the United States has to offer.
In my Blog of October 26, 2010, I described how the U.S. estate tax regime was in a state of flux. Without action by Congress before the end of 2010, U.S. estate taxes are set to revert back to the rates and exempt amount in effect in 2001.
So you are a Canadian citizen and resident, surely ‘Uncle Sam’ has no right to your Estate on your death. Unfortunately ‘Uncle Sam’s’ arm – his estate tax arm that is – can reach across the border to impose taxes on the Estate of a non-resident/non-citizen of the United States.
