U.S. citizens who die while resident in Canada face taxation issues from two countries: Canadian income tax on unrealized gains and certain tax deferred assets and U.S. federal estate tax on the fair market value of all assets. This blog briefly summarizes the tax issues and offers some suggestions on how to minimize U.S. federal […]

Last month, we described a situation where a Canadian resident, nonresident alien of the US used the Canada – US Income Tax Convention (“Treaty”) to reduce their overall tax liability on employment income earned in the U.S. The second part of our Treaty example concerns the use of Article XIII to treat gains similar for […]

Two recent client situations remind us that certain provisions in the Canada US Income Tax Convention (“Treaty”) can lower a client’s overall tax liability even where the answer isn’t so obvious when entering information in tax software. The first example is the subject of today’s blog. The second example will be posted later this month. […]