Will Todd is an independent lawyer who provides cross-border tax and estate planning advice to individuals and families from his downtown Vancouver office. INTRODUCTION A. Non-resident alien taxation 1. As a result, a major part of her practice is related to cross border U.S. – Canada transactions and estate planning, … For gifts, the recipient takes the donor’s original cost basis. A United States expat family, a U.S. person married to a non-citizen spouse, a non-U.S. person investing in the United States, and other cross-border families will need to have an investment plan that is correctly in sync with a tailored cross-border estate plan. Connections between Canadians and the U.S. have never been as numerous or transparent as they are now: many Canadians own U.S. property, have U.S. spouses or partners, and have … For transfers on death, in addition to receiving the distribution tax free, the beneficiary of a bequest will receive what is known as a “step-up in basis” to the fair market value of the asset on the date of death (or the alternative valuation date, 6 months after the date of death). Trusts are a primary method of devising a scheme of distribution that may allow some or all of the decedent’s assets to bypass probate, and (sometimes) to defer or avoid estate taxation. Access a 40% discount on the cost of purchasing European Cross-Border Estate Planning textbook, written by Timothy Lyons (Sweet & Maxwell). Finally, the concept of a trust is likely to be of little or no legal validity in a succession regime. Ask us a question now! Recently, Cirone’s practice has seen an increase in inquiries in the following areas: Planning and preparation of cross-border Wills (“CB Wills”) for U.S. citizens living in Canada. The transfer tax implications for the expat’s (or non-U.S. person’s) property will depend upon the interplay of: Situs is Latin for “position” or “site.” In the law, it is a term that refers to the location of the property for legal purposes. INTRODUCTION AND CASE STUDIES A. Be wary of trust structures when moving abroad If your estate plan includes trusts, we do not recommend moving abroad with your old domestic estate … While the global income taxation of U.S. citizens gets far greater attention, U.S. transfer taxes apply no matter where a U.S. citizen lives, gifts property, or dies. Indirect ownership can be a particularly effective means for non-U.S. persons to own U.S. real property, too. We work with families and individuals from a broad range of backgrounds and circumstances, creating customized plans to meet the unique needs of each client. (For more information, please see the relevant portions of the U.S. Tax Code including 26 U.S. Code § 2014 “Credit for foreign death taxes”). • Internal activities to satisfy our compliance, security and regulatory obligations; CROSS-BORDER ESTATE PLANNING: CANADIAN PARENTS OF U.S. CHILDREN U.S. transfer taxes (U.S. gift, estate and generation skipping taxes) should be a concern to any practitioner creating an estate plan with U.S. links. The dangers are not limited to the expat who relocates to a civil law jurisdiction. If you live a cross border lifestyle, we highly recommend speaking to our cross border tax experts to ensure you have a well structured estate plan to eliminate any future tax issues. Thun Financial Advisors is a Creative Planning, LLC company. KeatsConnelly can assist in your cross border tax planning needs. Cross-Border legal issues? Tax filing requirements as well as health insurance and risk management needs are other key cross border considerations that we analyze. Naturally, the likelihood that the effectiveness of an American’s existing estate plan will deteriorate will depend not only on where the family relocates, but also on how much the family integrates its wealth/assets/investments into the new country of residence, and for how long the expat family remains (or plans to remain) in the new country of residency. For instance, a special trust to benefit your family members may in certain cases minimize U.S. estate tax and protect your wealth. The magnitude of unintended tax consequences might intensify over time. Additionally, in Canada, which shares the British common law heritage, a special capital gains tax will be periodically assessed on trusts holding Canadian real property. It is extremely important to remember that the filer must specify any specific benefit under the treaty that is being claimed in the actual tax filings; otherwise, the presumed benefit is lost. Canadian parents are no strangers to losing their kids to the US – some may leave Canada to study in the US never to return, while others are recruited by US companies and sponsored by them for immigration purposes. Perhaps one of the more dangerous routes that an expat family could take would be to rely upon the estate planning that was done before leaving the United States. Tax filing requirements as well as health insurance and risk management needs are other key cross border considerations that we analyze. For example, consider a U.S. citizen who established a revocable grantor trust in favor of his children and grandchildren, but who thereafter moves to live and work overseas. Estate Disputes: Keeping the Peace. Cross-border estate planning lawyers Having a lawyer with experience in both Canadian and US estate planning is key. Recent estate tax law changes have significantly increased the federal estate and gift tax lifetime exclusion amount to very high thresholds: Accordingly, with a $22.4 million-per-couple exemption, most Americans feel that the estate tax is something that can be ignored. Cheyenne received her J.D. However, in most cases, individuals provide us their data directly. Estate planning cannot be done in a vacuum, and it requires experienced advisors who are knowledgeable about cross-border issues. • When you or a member of your immediate family seeks a confidential consultation with us; Given the critical fundamental legal differences in the distribution and taxation regimes around the world, it should come as little surprise that a family’s existing estate plan (designed for one legal system) may quickly become outmoded, ineffective, and even counter-productive once the family relocates overseas (and becomes subject to a completely different legal system). U.S. taxation – “exceptional” in reach and scope: America is “special” in many ways, but few aspects of American “exceptionalism” are as tangible as the way the U.S. Treasury levies taxes on its citizens who leave its borders to live and work abroad. These experts should also understand the myriad techniques that can mitigate the punitive effect of transfer taxes. INTERNATIONAL ESTATE PLANNING: PLANNING FOR THE CROSS-BORDER FAMILY I. TD Bank Tower Toronto-Dominion Centre66 Wellington Street West, Suite 3430P.O. Estate Planning Advisor. He adds, “Maybe have it in a cross-border trust or a partnership, or a vehicle that doesn’t die.” The goal is to bring the value of the estate below the amount that will trigger federal and state estate tax, and to avoid probate. In the process of regular business activity, we may collect certain basic personal data: Thun Financial is also committed to safeguarding and protecting the privacy of all visitors to its website or interested persons whom communicate personal and financial information with Thun Financial, whether potential clients or otherwise. Cross-border TAX FOCUS: WHAT THE 2020 U.S. PRESIDENTIAL ELECTION MEANS FOR CANADIANS. Join our mailing list to receive the latest news and updates on cross-border investing issues. Thun Financial Advisors does not render legal or tax advice to its clients or the public. Webinar: Cross-Border Estate Planning. Texas and Mexico share 1,254 miles of that border. Determining which country is the decedent/donor’s domicile for transfer tax purposes; Determining in which country the property is deemed to be located. Estate and Tax Planning for Cross-Border Families. Moreover, grandparents and great-grandparents can employ a 529-plan gifting strategy to shrink the taxable estate and to pass on wealth to grandchildren and great grandchildren (otherwise “skip classes” that would trigger generation skipping transfer (GST) taxes in addition to estate or gift taxes). Estateslawyertoronto.ca skilled lawyers can help with all cross-border estate family and estate litigation services with experience. Call us at 416-847-1859 ... Planning ahead for this transfer of property can eliminate lengthy procedures and ensure that your assets are protected from domestic and foreign estate … Including cross border financial, estate, investment, business, and tax planning. Only clients and prospective clients that engage in direct, confidential communications with us provide additional information. Additionally, estate tax may be owed on certain assets transferred to others within a fixed time period before death, or where the decedent retained an interest in the property. Qualified domestic trust (QDOT) – an important tool for marriages between a U.S. citizen and a non-citizen spouse: A QDOT is a type of trust designed to afford the surviving spouse the ability to claim use of and income from the decedent spouse’s estate during the lifetime of the surviving spouse, but then the QDOT assets will pass to the original decedent’s heirs upon the death of the surviving spouse. Please consult a licensed attorney or tax preparer regarding the suitability of any strategy, or the applicability of any rule or law, referenced herein, to your individual legal or financial circumstances. They also provide the donor with control over the use of the gifted proceeds and flexibility regarding the designation of account beneficiaries. Cross-Border Estate Planning You may need cross-border estate planning if you: Own a Canadian company with a U.S. subsidiary or that earns a significant amount of income in the U.S. Want to retire in the U.S. or spend a significant amount of time in the U.S. in retirement Conversely, the situs rules of the foreign jurisdiction will apply to that portion of the U.S. person’s estate that is deemed to have situs in that foreign jurisdiction. These are issues that extend beyond the scope of this guide, but certain issues can be discussed to illustrate the nuances involved in cross-border estate planning. In contrast, common law systems tend to have more concise constitutions and statutes and afford more discretion and interpretive power to the courts when applying the laws to the particular facts and circumstances of particular cases. Solution: Canadian tax advice and Ontario legal advice is necessary to effectively coordinate planning between California and the U.S. tax regime to avoid unintended consequences. The estate planning team must evaluate the interplay of the relevant transfer tax regimes and the pertinent treaty to determine the transfer tax outcome in consideration of not only the nature of the property and its location, but also the impact of citizenship and domicile on net tax outcomes. On the other hand, the majority of European, Latin American, and African nations have civil law systems. from the University of Victoria in 2005 and her Masters of Law Degree in International Taxation from New York University in 2006. The treaty rules establish taxation priority by first determining which jurisdiction was the domicile of the decedent. U.S. Courts have looked at a number of factors in determining the domicile of a decedent. The solutions or tools of estate planning and wealth management that could be utilized in any given situation may include (but by no means are limited to): Most of these tools are very familiar and frequently utilized by domestic financial planners and estate planning attorneys to assist single and multistate U.S. families. Both countries have different, often conflicting, tax rules about trusts and estates and … • When you browse or interact with our websites or access website research or other information; Section 529 college savings plans (see Thun Financial’s research article on 529 Plans for ex-pats) have grown substantially in popularity over recent years, as parents begin to realize the tremendous long-term advantages to saving larger amounts for college in earlier years for their children, and 529 accounts allow substantial deposits (as much as $150,000 in a one-time gift from joint filers covering a five-year period) and provide Roth IRA-style tax-free growth of the investment account, provided that the 529 plan assets are withdrawn for qualified educational expenses. Cross-Border Issues that Amplify the Complexity of Estate Tax Planning U.S. Estate Tax Basics. cROSS BORDER TRUSTS. Unfortunately, the tax complications and challenges facing American expats also extend to the circumstance of marrying a foreigner. Moreover, civil law succession regimes tend to prefer to impose tax upon inheritance (i.e., upon the heirs) at the time of distribution of the decedent’s estate rather than impose tax upon the estate of the decedent prior to the distribution of the decedent’s estate. That said, the U.S. federal estate tax regime may be described as in a state of flux, with some policymakers calling for its complete abolition, and others seeking to return the exemptions to much low-er levels. • During the initial or any ongoing financial planning process with a client; can also help with transfer taxes. These treaties among the pertinent jurisdictions will alter the path of estate planning. This field is for validation purposes and should be left unchanged. Frequently, it will make sense to own U.S. Real Estate through an offshore corporate or trust structure (for a foreign, non-resident investor only, as U.S. persons should certainly avoid offshore corporate or trust structures) to avoid U.S. estate tax, and possibly reduce U.S. income tax as well. Utilizing wills in international estate planning: Naturally, the will is one of the more common and widely utilized estate planning tools in the United States. Additionally, the countries may provide secondary credits where both countries impose tax because their individual situs laws determine that the (FATCA) create income tax problems that vastly outweigh any estate planning benefits. Cheyenne assists clients with tax, estate and trust planning. In civil law/forced heirship regimes, a fundamental problem exists when examining distributions to heirs through such a trust: the beneficiary is receiving the property from the trust, rather than a lineal relative (parent, grandparent, etc.). However, while U.S. expats are free to open and fund 529 college savings accounts, they must be aware of the local country rules in their country of residence regarding the gains that will eventually accumulate within these accounts. Avoid Serious Cross-Border Tax Issues with Effective Estate Planning. Michael Cirone is a Canadian and U.S. lawyer with 20 years of experience providing cross-border personal tax and estate planning services. More Publications Publication Canadians With U.S. From a tax perspective, the impact on the 2020 U.S. Presidential election will stretch well beyond U.S. borders. Accordingly, the QDOT can be a critical wealth planning tool for deferring the estate tax until distribution to eventual U.S. citizen heirs when the surviving spouse is a non-U.S. citizen. An expat should understand the particular definitions and requirements under the laws of the country(ies) in which they live, work, or own property. Concepts of citizenship, residency and domicile have crucial significance in determining the exposure of a person to the transfer tax regime of any particular country. Cross-Border Estate Planning Articles. This exposes distributions from the trust to potentially higher German transfer taxes. $11.4 million personal lifetime exemption (2019). We can help you understand how U.S. estate tax could affect your estate planning and how to minimize taxation in both jurisdictions through careful specialized estate planning. A specialist qualification that offers you a detailed insight into the different issues that arise when dealing with cross-border estate planning and succession worldwide. With a QDOT, only distributions from principal during the surviving spouse’s life and at the surviving spouse’s death are subject to estate tax (insofar as they exceed the original decedent spouse’s exclusion). This approach can allow for superior after-tax returns to help achieve important lifetime goals and greater wealth transfer to heirs. Currently, the vast majority of Americans, at home or abroad, have little concern for U.S. federal estate taxes. Our firm has decades of experience providing estate planning guidance and advice to families in Canada and the United States. There seems to be some risk in a strategy of multiple wills, as the traditional rule holds that the legal execution of a will extinguishes the validity of any property has situs in both (or even in neither) country. Americans living abroad may accumulate more than income and assets while living and working abroad, they may also find love! It is generally advisable to review an existing estate plan (and the broader financial plan) when major events (divorce, remarriage, etc.) The complexity and sophistication of traditional and living wills varies greatly, and any individuals with estates that may approach the levels that trigger any transfer taxes (which may be substantially lower in many foreign countries), or anyone who wants to make sure that their wishes are given legal effect, would be well advised to seek legal counsel regarding the drafting and execution of their will. A client may be subject to U.S. estate tax and married to a non-citizen spouse; a U.S. U.S. expats need to be aware that standard U.S. estate planning techniques will likely fail to protect wealth in cross-border situations and may even produce unintended, counter-productive results. Michael Cirone is a Canadian and U.S. lawyer with 20 years of experience providing cross-border personal tax and estate planning services. Cross border trust and estate planning . You may have a serious estate tax issue if you are a US citizen and have used a typical Canadian estate … On the other hand, the $11.4 million (2019) lifetime exclusion applies to bequests left to anyone, including a non-citizen spouse. Info Here > US ESTATE AND GIFT PLANNING. More sophisticated estate planning tools become necessary at more modest estate levels whenever the assets of a non-U.S. person are concerned. MCA Cross Border Advisors, Inc. is a registered investment adviser. In short, since no one can confidently predict where the estate tax exclusion, marital deduction and tax rate levels will be in the future, ignoring estate planning based on current tax thresholds may be a costly mistake. Canadians Living in the U.S. For example, to return to the aforementioned global family from earlier (U.S. husband, French wife, and child living in Germany, with two U.S. children from husband’s prior marriage living in the U.S.), the tax-conscious financial plan can go beyond the routine suggestion of a QDOT, and actually design investment portfolios that will minimize potential income and transfer taxes in a comprehensive wealth management strategy. These “permitted” uses may include: Our small size and our proximity to the capital of Europe, Brussels Belgium, enable us to deliver timely and personalized service to manage these challenging cross border issues.Contact us today to learn more about how Cross Border Planning can streamline and … Correctly tailoring that cross-border estate plan will require legal and tax experts with a deeper understanding of the relevant estate/ succession/gift/generation-skipping transfer (collectively Moreover, while each sovereign has their own rules and interpretations of situs rules, the U.S. regime can be somewhat instructive for other countries’ situs rules. Acquisition of real estate. Cross Border Planning provides a coordinated solution for those who have financial affairs in more than one land. Cross Border Estate Planning for Canadians. Even if an expat’s spouse obtains U.S. permanent resident (“green card”) status, gifts and bequests to the non-citizen spouse are not eligible for the unlimited marital deduction. Despite its importance, cross-portfolio investment optimization is something that is seldom discussed in a meaningful way, much less implemented effectively. Common law vs. civil law foundations: While the estate tax laws of different U.S. states may have critical differences (e.g., the recognition and/or treatment of community property), these differences are subtle in comparison to the international landscape. Whether the property is situated in the foreign country; Whether the property is subjected to transfer/death taxes; Whether the property is properly included in the gross estate. In short, Section 529 college savings accounts provide tremendous income and transfer tax-advantaged gifting opportunities to accomplish multigenerational wealth transfer. The nature, timing, and documentation of the gifts should be done with the assistance of a knowledgeable tax and/or legal professional. Introduction Few countries enjoy the close, friendly relationship enjoyed by Canada and the United States. Will Todd is an independent lawyer who provides cross-border tax and estate planning advice to individuals and families from his downtown Vancouver office. He adds, “Maybe have it in a cross-border trust or a partnership, or a vehicle that doesn’t die.” The goal is to bring the value of the estate below the amount that will trigger federal and state estate tax, and to avoid probate. At present, the recently doubled exemp-tions are slated to sunset in five years (2023), returning to pre-2017 tax reform levels. If an individual and his or her family have ties across the border, either through residency, citizenship, domicile or the location of an asset, it is important to obtain legal advice from experienced lawyers who can assist in identifying critical issues and preparing a coordinated and effective cross-border estate plan. Cross-border estate planning requires the skill and knowledge of a qualified lawyer with experience in resolving these complex issues. to understand that the standard U.S. estate plan may no longer protects wealth as intended. The Tyra Law Firm, LLC Helping our neighbors plan for their family’s future and avoid painful issues. This is analogous to the intestate succession rules followed in common law when the decedent has otherwise failed to legally direct the distribution of wealth upon death. Alternative college savings or generational gifting strategies (including having U.S. based relatives open the 529 account) may work better for expats. Portability of unused exemption to surviving spouse: Beyond that, if the first-to-die spouse’s exemption amount is not fully utilized, an election on that estate tax return will preserve the remaining unused exemption amount for the second-to-die spouse. Thun Financial Data Privacy Statement Designed, written and delivered by leading industry experts. The utilization of offshore PICs is generally no longer utilized for U.S. clients, because Passive Foreign Investment Company (PFIC) rules and the Foreign Account Tax Compliance Act prior will. There are a number of strategies that can help minimize the amount of tax that must be paid by the estate following death. January 20, 2017. Within the cross-border context, individuals would be wise to seek legal counsel with a specialized focus on estate planning in the relevant jurisdictions. This is an introductory webinar on the cross border Estate Planning issues facing Australian expatriates living in the United States. For ex-ample, the UK has three residence statuses that impose different rules based on length of residency or election of status: resident, domiciliary, or deemed domiciliary. A United States expat family, a U.S. person married to a non-citizen spouse, a non-U.S. person investing in the United States, or other families with multiple nationalities, will need to have an investment plan that is correctly in sync with a tailored cross-border estate plan. However, PICs may be instrumental in the financial plan of a non-U.S. person investing within, or outside of, the United States. For instance, all or part of your estate may be or become subject to U.S. estate tax if: There is a special tax treaty between Canada and the U.S. that provides various types of relief from double taxation on death. By Heela Donsky Walker April 13, 2015. Cross-Border Estate Planning Those with assets, loved ones, or tax exposure on both sides of the Canada-US border face unique estate planning challenges. Cross-Border Estate Planning March 23, 2017. If you own assets in both Canada and the United States, or you or your family members have connections to both countries, either by citizenship, residence or domicile, and you are seeking to create an estate plan that optimizes your situation, please call our Toronto, Ontario law office. The four combinations mentioned in the abstract above may be depicted graphically as on page 40 of this issue of Trusts & Trustees, in the article ‘Cross-Border Planning For Real Estate: Austria’ by Niklas Schmidt. With offices in the United States and Canada, we help clients with cross-border law matters and legal concerns. Offering cross-border wealth management solutions. This example merely highlights that certain classes of investments may be subject to more draconian reporting and taxation rules than other investments. Permanent resident (green card) status would in most (but not necessarily all) cases establish domicile. While non-U.S. investors and non-citizen spouses present obstacles for certain common traditional estate planning tools (e.g., joint ownership), knowledge of U.S. situs rules can be utilized to con-struct family portfolios that are particularly U.S. income tax and U.S. estate tax efficient. You, your children, your spouse or one of your beneficiaries is domiciled in the U.S. You own real estate or personal property located in the U.S. or other U.S. situs property, including shares of U.S. corporations. Thun Financial Advisors Privacy Statement was updated in May, 2018, and may be amended from time to time to reflect updated legal requirements or evolving best practices in data collection and protection. If you would like to review our data privacy statement, click here. We will otherwise only use your personal data internally in connection with our ordinary professional activities as an investment advisory firm. Some experts on the subject of international estate planning suggest multiple “situs” wills, with each will governing the distribution of property in the country for which the will is executed. Full details of how to take advantage of the discount are included on the online learning platform. In contrast with many succession/heirship-based transfer tax systems abroad, gifts and inheritances in the United States are not taxed to the beneficiary of the gift or bequest, because we have a transfer tax system that taxes these transfers at the source of transfer (i.e., the donor, grantor, or the estate). CROSS-BORDER ESTATE PLANNING By: Gideon Rothschild Moses & Singer LLP 405 Lexington Avenue New York, New York 10174 (p ) (212 ) 554-7806 (f ) (212 ) 554-7700 grothschild@mosessinger.com www.mosessinger.com I. Make sure your tax, estate planning, pensions and investment approach is tailor-made for you with specialist, personalised advice. In a cross-border context, it is wise to seek legal counsel with a specialized focus on estate planning in the relevant jurisdictions. Home | Cross-Border and Multijurisdictional Estate Matters | U.S.-Canada Cross-Border Will and Estate Planning. The following article addresses U.S. estate tax consequences of a family comprised of Canadian Estate tax treaty “tiebreakers” and the new/old situs rules: Another key effect of tax treaties is that they establish tie-breaker rules. Chair. For example, the situs rules discussed earlier illustrate that investments in U.S. publicly traded fixed-income (bonds) will not subject the foreign investor to estate taxes (nor income taxes). Whether you have general business transactions or international disputes, are travelling or a snow bird, we can help you with cross-border representation or legal services. Currently, the United States has estate and/or gift tax treaties with sixteen sovereign nations (see Appendix A). The domiciliary country may tax all transfers of property within the entire estate, while the non-domiciliary country may only tax real property and business property with situs in that country. We provide an array of cross-border estate planning services, including: Our firm is known in the professional community for its ability to create and effectively deliver legal solutions for succession of assets and estate and incapacity planning for clients with connections to both Canada and the U.S. As an internationally-recognized firm that frequently deals with clients with multijurisdictional issues, our legal team can provide you with advice regarding your cross-border estate planning needs. Now! ” button below of real estate to estate planning can become complicated the... Are also able to provide us with lists of personal data internally in connection with our ordinary professional activities an. Assist in your shopping cart Description: join our mailing list to the! 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