US Taxes

Total 46 Posts

An Inconvenient Truth: Cross-border Estate Barriers for Non-Resident Executors

Today’s blog comes to you from Student-at-Law, Derrick Raphael. As a new resident of Canada there are several issues that an individual must consider such as tax implications while residing in the country as well as one’s previous jurisdiction. Additional areas of interest regard how to manage assets, property and other investments when an estate needs to be distributed. Personally as a newcomer to Canada I had yet to think about….

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Estate Planning, Tax Issues, Uncategorized, United States, US Taxes, Wills

Not All “Trump Bumpf” is Bluster

As part of the ‘Donald’s’ post-election “promises” we heard rumours that US gift and estate taxes were going to be repealed.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

Inheritances and Taxes – Be Careful Where you Step?

Frequently, I am reminded how careful one has to be with making sure that tax-free inheritances generally maintain their status throughout all steps to liquidate and realize the proceeds. Here is a case in point. In Owen v The Queen (2018 TCC 90), the taxpayer’s father resided in the United States of America and had a US individual retirement account (“IRA”). The taxpayer’s father passed away. The taxpayer and his….

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Canada Revenue Agency, Estate Administration, Estate Planning, Investments, IRS, Property, Tax Issues, Uncategorized, United States, US Taxes

INCOME FROM A U.S. TRUST: CAN IT EVER BE TREATED AS DIVIDEND INCOME?

Sometime ago, a relative of a Canadian taxpayer died in the US and she left her money in a charitable trust, with some of the income bequeathed to the Canadian taxpayer annually. The trust income is derived mostly from US dividends. With a series of proposed adjustments to her personal tax returns, the taxpayer asked the Canada Revenue agency (“CRA”) why this income could not be treated as dividend income….

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Canada Revenue Agency, Canadian and US Tax Treaty, Estate Administration, Estate Planning, Interest, Investments, Tax Issues, Trusts, United States, US Taxes
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