Cross-Border Tax Analysis
Cross-border tax advice and technical analysis for US persons in Canada.
- Inbound/outbound migration
- Latest Development
- Treaty Interpretation
- Trust, Estates and Wealth Transfer
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U.S.-Situs Property for Canadian Residents: Determining Which Assets May Be Subject to U.S. Estate Tax
Learn which assets may be considered U.S.-situs property for Canadian residents, including U.S. real estate and shares of U.S. corporations, and why identifying these assets is an essential first step in U.S. estate tax planning
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Bruyea Reversed: The Canada-U.S. Treaty Does Not Shelter NIIT
The Federal Circuit’s Bruyea decision confirms that Canadian income tax cannot be credited against U.S. Net Investment Income Tax (NIIT), with important implications for U.S. citizens residing in Canada.
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U.S. Estate Tax Considerations for Canadian Residents: An Overview
Canadian residents who own U.S. property or investments may be exposed to U.S. estate tax, even if they have never lived in the United States. Learn how U.S.-situs assets, treaty relief, and filing requirements can affect cross-border estate planning.
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Canadian Exit Tax: Deemed Disposition on Emigration
Canadians relocate to the United States for a range of reasons, including career opportunities, business expansion, family considerations, education, or…
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Moving from the US to Canada: Technical Consequences of Entering a Second Worldwide Tax System
There has been an increasing trend of U.S. persons relocating to other countries in recent years due to a variety…
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Entering the U.S. Tax System: A Structural Approach to Pre-Residency Tax Planning
There is a fundamental difference between being taxed by the United States as its tax resident and merely investing in…
