Canadian and US Tax Treaty

Total 21 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

The Principal Residence Exemption and U.S. Citizens

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A U.S. citizen living in Canada is in a uniquely complex position when it comes to the taxation of their principal residence. While both countries provide tax relief for gains on a “principal residence,” the interaction between the two systems often creates unexpected cross-border tax consequences. Canadian Principal Residence Exemption The principal residence exemption (PRE) is one of the most well-known and generous provisions in the Canadian tax system. If….

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Canadian and US Tax Treaty, IRS, Real Estate, U.S. Citizen, United States, US Taxes

Dual Citizens, U.S. and Tax

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Dual U.S.-Canadian citizens residing in Canada may want to pay particular attention to the Exclusive Citizenship Act of 2025 (the “Act”); a proposed bill establishing that “citizens of the United States shall owe sole and exclusive allegiance to the United States […]”.[1] Under the proposed bill, dual citizens have one (1) year from the date of the enactment of the Act to submit a written renunciation of their foreign (e.g…..

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Canadian and US Tax Treaty, 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

Tariffs and Estate Planning

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This blog post was written by Dave Madan, Senior Manager, Scotiatrust Following President Trump’s announcement of “Liberation Day,” Canadians are contemplating the reasons behind this decision. Amidst this uncertainty, many Canadians have re-evaluated their relationships with the United States, encompassing their daily interactions, financial affairs, and future planning. The purchase of American goods has been supplanted by Canadian alternatives. Investments in American companies have been replaced by domestic investments, and….

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Canadian and US Tax Treaty, Estate Planning, United States, US Taxes

ILIT – An Estate Planning Vehicle for the U.S. Person

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An irrevocable life insurance trust (ILIT) is an estate planning vehicle worth some consideration for U.S. citizens living in Canada.  Many estate advisors are unaware that U.S. citizens subscribing to life insurance on their life will have the death benefits included in the value of their taxable estate for U.S. estate tax purposes.  An ILIT may provide an opportunity to avoid such an outcome. What is an ILIT? An ILIT….

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Canadian and US Tax Treaty, Estate Planning, Insurance, Succession Planning, Tax Issues, U.S. Citizen, US Taxes
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