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U.S. Tax Implications of Using a Non-U.S. Trust

Philip Mei 03/16/2026

Canadian trusts are commonly used in Canadian estate and succession planning. While effective for Canadian planning, they often create additional disclosure requirements or adverse U.S. tax consequences when one or more trust parties live outside Canada. To determine how a trust is taxed for U.S. ...

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How the Proposed Amendment to the Trust-to-Trust Transfer Rules Could Impact Your Clients

Dale Franko 03/03/2026

On January 29, 2026, the Department of Finance requested views and feedback (the “Consultation”) on the draft legislative proposals contained in the November 4, 2025, budget (“the 2025 Budget”. Specifically, the Consultation includes, among other things, the “21-Year Rule”. By way of background, the 21-year ...

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Changes to IRS Refund Payments Beginning in 2026

Paula Owen 02/25/2026

Canadian residents who file U.S. tax returns should be aware of upcoming changes to how the IRS issues tax refunds. The U.S. Treasury is moving toward electronic-only federal disbursements, which will affect refund delivery beginning with the 2025 tax year (2026 filing season). Current Refund ...

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Investing in U.S. Publicly Traded Partnerships: What Non U.S. Investors Need to Know About U.S. Tax and Compliance

Paula Owen 02/23/2026

As Canadian investors continue to look south for diversification and income, U.S. publicly traded partnerships (PTPs) often come up as potential opportunities. While these investments can be attractive, they carry U.S. tax implications that are very different from owning U.S. stocks and are often overlooked. ...

Tax Issues Facing Canadian Technology Entrepreneurs who move to the U.S.

Steven Flynn, CPA, CA, CPA (Washington) 02/11/2026

One advantage Canadian entrepreneurs in the technology space have over those in other industries is mobility. Whether from the demands of their business or a lifestyle choice, many choose to relocate from Canada to the United States. Canadian Departure Tax An individual ceasing Canadian residency ...

Selling U.S. Real Property in 2025: Avoiding Tax Pitfalls and Refund Delays for Canadian Residents

Steven Flynn, CPA, CA, CPA (Washington) 04/10/2025

In 2020, Canadians faced critical decisions on what to do with their U.S. real property interests. Due to travel restrictions from the Covid-19 pandemic, many could not visit the U.S. as usual. At the same time, prices in many U.S. markets increased dramatically – giving ...

Washington State Estate Taxes

Andersen 02/04/2025

Many thanks to Michael Mashni from Andersen Seattle for his assistance with this blog Canadians who are not US persons (not US citizens or US domiciles) are subject to US federal estate tax on the value of US situs assets they own on their date ...

Capital Gain Reversal: Much Ado About Nothing

Andersen 02/02/2025

On Friday, the Honourable Dominic LeBlanc, Minister of Finance and Intergovernmental Affairs, announced that the federal government is deferring—from June 25, 2024 to January 1, 2026—the date on which the capital gains inclusion rate would increase from one-half to two-thirds on capital gains realized annually ...

U.S. Fifth Circuit Court granted appeal to lift injunction on CTA reporting:

Andersen 01/06/2025

Federal Appeals Court Lifts Block on Anti-Money Laundering Law In a significant legal development, a federal appeals court has lifted an order that had blocked the nationwide enforcement of the Corporate Transparency Act (CTA). This anti-money laundering law mandates that corporate entities disclose the identities ...

U.S. Citizens Resident in Canada – Capital Gains Tax Rate

Steven Flynn, CPA, CA, CPA (Washington) 01/06/2025

What should be a straightforward answer gets complicated by recent events in Canadian Parliament and a recent US Tax Court Case. Current Law A U.S. citizen resident in Canada is subject to both U.S. federal income tax and Canadian on their worldwide income. In 2023, ...

The member firms of Andersen in Canada focus on Canadian, international and Canada-U.S. cross-border tax matters. With offices across Canada, our tax professionals work with a broad range of businesses and individual clients to develop innovative tax solutions for a diverse range of issues. Our senior leaders and many of our professional staff have extensive experience in Canadian, international, U.S. and cross-border tax matters with major international accounting firms, as well as practical experience working with businesses and individuals.

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