IRS

Total 23 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

U.S. Estate Planning & Step-Up in Basis: A Key Rule for Inherited Assets

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When advising Canadian clients with cross-border estate planning considerations involving U.S. beneficiaries, the step-up in basis is an important tax concept that can materially affect the beneficiary’s after-tax outcome. A step-up in basis is a significant U.S. tax rule that may affect the capital gains tax payable when inherited assets are later sold. In general, an asset’s tax basis begins with its original purchase price and may be adjusted for….

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Estate Planning, IRS, Succession Planning, Tax Issues, U.S. Citizen, 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

Surrogacy Across Borders: What Canadian Families Need to Know

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Today’s blog was co-authored by Pahul Sond, Student-at-Law, at Fasken LLP Surrogacy is a life-changing journey—but when it crosses international borders, the process becomes more complex. This post highlights a recent CTV news story, applicable laws in Canada, and a Q&A I conducted with a friend who recently went through the journey. Canadian Surrogate Turned Away at the Border A recent CTV News story titled “U.S. border officers turn back….

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In the News, IRS, United States

Canadians Beware – U.S. Move To End Paper Cheques for Federal Payments

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On March 25th, 2025, President Donald Trump issued Executive Order 4247 (“EO 4247”) directing the U.S. Department of the Treasury to transition all federal disbursements and collections into electronic format; effectively ending the use of paper cheques. By September 30th, 2025, paper cheques for federal payments (notably tax refunds and social security payments) will cease. How is this relevant to Canadians? Hurdle for Canadians EO 4247 may represent a hurdle….

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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
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