Canadian and US Tax Treaty

Total 20 Posts

CAPITAL DIVIDENDS FROM A TRUST TO NON-RESIDENTS – TAX ISSUES

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Subject to the relevant sections of the Income Tax Act, a Canadian private corporation has a special corporate tax account known as a capital dividend account (“CDA”) which gives shareholders designated capital dividends, tax free. The CDA of a corporation may include the non-taxable portion of the company’s capital gains, proceeds of life insurance policies on death and capital dividends received from other companies. While a capital dividend is normally….

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Canada Revenue Agency, Canadian and US Tax Treaty, Estate Administration, Estate Administration and Probate Applications, Estate Planning, Executors, Investments, Property, Small Business, Tax Issues, Trustee, Trusts, U.S. Citizen, United States

More on Graduated Rate Estates

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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 one will. Definition of a GRE The CRA was asked that while an estate is under administration during its first….

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Business Succession Planning, Canada Revenue Agency, Canadian and US Tax Treaty, Estate Administration, Estate Administration and Probate Applications, Estate Planning, Executors, In the News, Probate Tax, Succession Planning, Tax Issues, Trustee, Trusts, Wills

OWNERSHIP OF FOREIGN PROPERTY

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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…….

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Canadian and US Tax Treaty, Estate Administration and Probate Applications, Estate Planning, Power of Attorney, Probate Tax, United States, US Taxes, Wills

ALTERNATIVES TO ‘SINGLE-PURPOSE’ CORPORATION FOR U.S. ESTATE TAX PLANNING

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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…..

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Canada Revenue Agency, Canadian and US Tax Treaty, Estate Planning, Investments, IRS, Property, Succession Planning, Trusts, United States, US Taxes

Tax Reporting Obligations for Trustee and Executor Fees

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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.
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Canada Revenue Agency, Canadian and US Tax Treaty, Estate Administration, Estate Planning, Executors, Liability, Passing Of Trustees’ and Executors’ Accounts, Trustee, Trusts
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