International

Total 44 Posts

The End of the Delinquent FBAR Safe Harbour: What U.S. Persons and Advisers Need to Know

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On June 30th, 2026, the Internal Revenue Service (“IRS”) removed its “Delinquent FBAR Submission Procedures,” representing a significant development for U.S. persons with foreign financial accounts who have failed to file the required Reports of Foreign Bank and Financial Accounts (commonly referred to as “FBAR”). While the statutory framework governing FBAR filing obligations and penalties remains unchanged, the removal of this administrative procedure creates greater uncertainty for taxpayers seeking to….

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Canadian and US Tax Treaty, International, IRS, Tax Issues, U.S. Citizen, United States, US Taxes

Clarifying U.S. Estate Tax for Canadians

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It comes as a surprise to many Canadians to learn their estate may be subject to U.S. estate tax. Indeed, the U.S. estate tax regime is broad and complex and misunderstood by many Canadians. This article will provide a summary overview of its application to Canadian and how to minimize its implications. U.S. Estate Tax Regime in General All U.S. persons (U.S. citizen, U.S. resident or green card holder) are….

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Canadian and US Tax Treaty, Estate Planning, International, IRS, Tax Issues, US Taxes

Cross-Border Charitable Donation & U.S. Donor

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Philanthropy can strengthen one’s estate plan. In Canada, an estate plan may integrate charitable donations to leave a legacy to our community while taking advantage of the associated tax benefits. Such strategy can be implemented during the donor’s lifetime or upon the donor’s death. If the donor is a U.S. citizen living in Canada (hereinafter referred as a “U.S. donor”), does the strategy work? U.S. donor & U.S. Tax Filings….

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Charitable Giving, International, Philanthropy/Charitable Giving, Tax Issues, U.S. Citizen, US Taxes

Joint Ownership & U.S. Estate Tax Considerations

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Canadians are familiar with the concept of joint ownership with right of survivorship. It is the prevalent form of ownership between spouses. Therefore, it is not uncommon for Canadians to own U.S. real property or other U.S. property, jointly, especially between spouses. Many are of the view that it will simplify the estate plan and succession of the U.S. property to the surviving owner yet, few understand the U.S. estate….

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International, Joint Tenancy, Real Estate, Succession Planning, Tax Issues, United States, US Taxes

Provincial Succession Law and Family Law

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One of the most interesting and challenging aspects of working in the trusts and estates field is how different the rules can be, not just internationally, but within our national borders. For example, this week I was chatting with my Quebec colleagues about Bill 56 – An Act respecting family law reform and establishing the parental union regime. It amends provisions of the Civil Code of Quebec (the “Code”) and….

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Family Conflict, International, Spouse, Succession Planning

Estate Administration and China

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This article discusses, at a high-level, estate administration in China and some considerations when someone inherit assets located in China. As mentioned in my previous article, planning for cross-border estate administration with China is complex thus, I must admit the information is general in nature and based on my personal experience. China’s Estate Administration When it comes to estate administration involving moveable or immovable property in China, one can assume….

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China, Estate Administration, Estate Administration and Probate Applications, Estate Planning, International
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