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Total 23 Posts

TAX CONSIDERATIONS FOR GIFTS OF SHARES IN CANADA

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Gwenyth Stadig, Natasha Barrett, Upama Poudyal, Abdullah Khalid, Amber LeBlanc all of Gowling WLG (Canada) LLP Canadian donors can donate a variety of types of property to “qualified donees” which gift can be eligible for donation tax credits. Subsection 149.1(1) of the Income Tax Act (“ITA”) defines the term “qualified donee” (“QD”) to include Canadian registered charities. The Canada Revenue Agency (“CRA”) maintains a list of QDs here. The nature….

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Canada Revenue Agency, Charitable Giving, Estate Donations, Interest, International, Investments, IRS

U.S. Filing Requirements for Canadian POAs, Joint Accounts, and Bare Trusts

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This article is written by Nicole Ewing, Director, Tax & Estate Planning, TD Wealth Whether it’s a Power of Attorney (POA) for Property document, a joint account, or a bare trust relationship, if a U.S. person’s involved, things can get complicated quickly. Canadians without U.S. ties can find themselves and their assets subject to the scrutiny of U.S. authorities simply by engaging in common estate planning activities. One such issue arises….

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Estate Planning, IRS, Power of Attorney, Tax Issues, United States, US Taxes

Cross-Border Insurance Planning – Some Basics

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Cross-border insurance planning is tricky but understanding the basics can go a long way in assisting clients. This short article will review some of the key questions to consider in order to avoid potential pitfalls in life insurance planning. Who is the Owner, the Insured and the Beneficiary In the context of personal insurance planning, it is important to appreciate that there are always three (3) parties involved; the owner,….

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Estate Planning, Insurance, International, IRS, Succession Planning, Tax Issues, U.S. Citizen, US Taxes

Corporately-Owned Insurance, Redemption Obligations and the U.S. Supreme Court

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Canadian estate and tax advisors may want to consider the case Connelly v. Internal Revenue Service, No. 23-146[1] (U.S. 3/27/24).  The U.S. Supreme Court (“SCOTUS”) issued its decision on June 6th and it serves as a good reminder of the implications of corporately-owned life insurance in the context of cross-border tax and estate planning for Canadian estates. The issue focused on the estate tax treatment of corporately-owned life insurance proceeds….

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Estate Planning, Insurance, IRS, Tax Issues, U.S. Citizen, United States, US Taxes, valuation

The Importance of the U.S. Federal Transfer Certificate

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Canadians often misunderstand (or are unaware) that the U.S. estate tax may apply to their estate.  Indeed, if a Canadian dies owning U.S. situs assets with a gross value exceeding USD $60,000, their estate will have to file a U.S. estate tax return and, depending on the worldwide fair market value of their estate, could be subject to U.S. estate tax. From an estate administration perspective, one of the challenges….

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Executors, IRS, Succession Planning, Tax Issues, U.S. Citizen, United States, US Taxes

U.S. Gift Tax – It May Apply To Canadians

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The U.S. gift tax is often overlooked by Canadians and their advisors. Most U.S. citizens living in Canada are aware of the U.S. estate tax and gift tax application. However, when it comes to Canadian residents who are not U.S. persons, only a minority are aware of the potential application of the U.S. gift tax. The author admits, the U.S. gift tax rarely applies to Canadian residents and this blog….

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Estate Planning, IRS, Tax Issues, United States, US Taxes
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