US Taxes

Total 45 Posts

ILIT – An Estate Planning Vehicle for the U.S. Person

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An irrevocable life insurance trust (ILIT) is an estate planning vehicle worth some consideration for U.S. citizens living in Canada.  Many estate advisors are unaware that U.S. citizens subscribing to life insurance on their life will have the death benefits included in the value of their taxable estate for U.S. estate tax purposes.  An ILIT may provide an opportunity to avoid such an outcome. What is an ILIT? An ILIT….

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Canadian and US Tax Treaty, Estate Planning, Insurance, 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

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

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

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

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In circumstances where clients, who are Canadian residents, intend to equalize their estates amongst their children (“Equalization Intention”) where one or more of such children are “U.S. Persons” (a “U.S. Child”), estate planners need to consider whether that is possible and if so, how (“whether” and “how”, the “Questions”).  This is Part I of a three-Part blog series discussing a few considerations that tax and estate advisors may wish to….

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

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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