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Total 21 Posts

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

Considerations when Administering a Canadian Estate with US Situs Assets

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Today’s blog is written by Jessica J. Butler, Law Clerk at Fasken LLP. As today’s world continues to grow increasingly interconnected, more estate professionals find themselves dealing with a web of cross-border assets and jurisdictional issues.  This post considers certain issues that you might face when administering a Canadian estate with assets situated in the United States. Legal Authority You must first determine whether you will need legal authority to….

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Canadian and US Tax Treaty, Estate Administration, International, IRS, Probate Tax, Tax Issues, United States, US Taxes, Wills

Not All “Trump Bumpf” is Bluster

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As part of the ‘Donald’s’ post-election “promises” we heard rumours that US gift and estate taxes were going to be repealed. While we did not see a repeal, we did see a significant change to the rules related to US gift and estate tax. The particular change came forward in the US Tax Cuts and Jobs Act (“TCJA”) which was signed into law on December 22, 2017. Specifically, the amendment….

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