United States

Total 60 Posts

Of Millionaires and Migration

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This blog has been written by Rahul Sharma, Partner, at Fasken Martineau DuMoulin LLP, Toronto Last week, I had the pleasure and privilege of being a panelist at the American Bar Association’s International Law Section conference in London, UK.  The focus of our discussion was millionaire migration.  Together with my co-panelists from different global jurisdictions, we discussed, most particularly, our observations of where high and ultra-high net worth people are….

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Estate Planning, Tax Issues, United States, Wills

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

Equalizing an Estate Where One of More Children are U.S. Persons and Planning Strategies Where There Are U.S. Beneficiaries; Part III

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This is Part III of a three-part blog series. Parts I & II can be found at the following respective links: https://allaboutestates.ca/equalizing-an-estate-where-one-of-more-children-are-u-s-persons-and-planning-strategies-where-there-are-u-s-beneficiaries-part-i/ and https://allaboutestates.ca/equalizing-an-estate-where-one-of-more-children-are-u-s-persons-and-planning-strategies-where-there-are-u-s-beneficiaries-part-ii/. Parts I & II discussed a few issues to consider if a client’s intention is to equalize their estate amongst their children where one or more children are U.S. Persons (such U.S. children, a “U.S. Child”). This Part III builds on Parts I & II and….

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Estate Planning, Executors, Tax Issues, Trusts, United States, US Taxes, Wills

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

Equalizing an Estate Where One of More Children are U.S. Persons and Planning Strategies Where There Are U.S. Beneficiaries; Part II

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  Happy Friday, everyone. As a reminder, this is Part II of a three-part blog series. Part I can be found at the following link: Equalizing an Estate Where One of More Children are U.S. Persons and Planning Strategies Where There Are U.S. Beneficiaries; Part I – All About Estates and Part III, to be posted August 30, 2024, will discuss estate planning in circumstances wherein there are U.S. beneficiaries…..

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Estate Planning, Tax Issues, Trusts, U.S. Citizen, United States, US Taxes, Wills

Beneficiary of a U.S. Estate – Now What?

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What are the tax implications if you are a beneficiary of a U.S. estate? Rarely do we consider the implications of a Canadian resident inheriting from a U.S. estate. From a Canadian Tax Perspective The general rule is the Canadian beneficiary shall receive their inheritance tax-free since the U.S. estate is deemed to have acquired the assets at fair market value (i.e. cost-base step-up). Further, if the executor is a….

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Estate Planning, International, Succession Planning, Tax Issues, Trusts, United States
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