U.S.-Canadian Tax and Estate Planning for Dual Residents
Reconciling U.S. and Canadian Law on Trusts, Deemed Dispositions on Death, Situs Wills, and Wealth Transfers
Note: CPE credit is not offered on this program
Recording of a 90-minute CLE webinar with Q&A
This CLE webinar will provide estate planners with a comprehensive guide to estate planning tax challenges and opportunities for clients who have a tax presence in both the United States and Canada. The panel will discuss the U.S. tax law and treaty provisions that govern tax and fiduciary rules in both Canada and the United States. The webinar will focus on the U.S. tax and other consequences for Canadian clients with U.S. tax presence and U.S. taxpayers with Canadian-based pensions and other assets.
Outline
- U.S. estate tax regime
- Canadian "deemed disposition" rules
- Tax treaty credit provisions
- U.S. and Canadian tax treatment of trusts
- Filing and reporting deadlines and timelines to consider
Benefits
The panel will review these and other essential issues:
- When is it appropriate for clients to have separate estate plan documents specific to the U.S. and Canada?
- How does the "deemed disposition" rule work to create a recognition event upon death or transfer of assets deemed to be Canadian-sourced?
- What are the tax treaty provisions to ameliorate dual taxation issues in estates and post-mortem tax events?
- How to avoid inadvertent gift tax triggering events on spousal transfers
- Options for transferring estate assets outside of an estate in Canada
Faculty

David A. Altro
Managing Partner
Altro
Mr. Altro has been practicing law for over 30 years in Canada and the US and divides his time between the Toronto and... | Read More
Mr. Altro has been practicing law for over 30 years in Canada and the US and divides his time between the Toronto and Montreal offices. He specializes in cross border tax, estate planning and real estate for high net worth individuals and has written articles for numerous legal and industry publications.
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Bradley R. Thompson
Partner
Altro
Mr. Thompson is a leading cross-border Canada/US tax lawyer. Educated in both countries and qualified as a lawyer in... | Read More
Mr. Thompson is a leading cross-border Canada/US tax lawyer. Educated in both countries and qualified as a lawyer in both New York and Ontario, he has practiced at large international firms in both jurisdictions. Mr. Thompson now provides comprehensive tax advice to businesses and high net worth individuals with a cross-border Canada/US footprint. He has extensive experience with complex corporate transactions in the cross-border context such as M&A transactions, financings, and joint venture structuring. Mr. Thompson also has deep experience advising families on the individual tax consequences of their cross-border lifestyles. He has advised clients in a wide range of industries, including real estate, technology, manufacturing, professional services, and private equity.
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Samantha Y.F. Wu
Partner
Altro
Ms. Wu's practice focuses on cross border estate planning and real estate.
| Read MoreMs. Wu's practice focuses on cross border estate planning and real estate.
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