At a recent conference of the Society of Trust and Estate Practitioners, the Canada Revenue Agency (“CRA”) was asked to respond to certain questions regarding Graduated Rate Estates (GRE’s), in particular around the actual definition of a GRE and its application to a situation where the deceased has more than…
Category: Canadian and US Tax Treaty
Total 17 Posts
The Huffington Post reports that over a third of foreign buyers of real estate in Florida are Canadians. Another article reports that Canadians are the leading buyers of US real estate. In earlier blogs I’ve talked about the specter of US estate taxes that arises when a Canadian dies owning US situs property, like real estate. Besides this complexity, the ownership of foreign property raises the potential for challenges in the administration of an estate. As a result, when developing an estate plan that includes foreign real estate it is important to consider a number of issues, some of which are…
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.