U.S. Estate Taxes for Canadians

Many Canadians are surprised to learn that they may be subject to U.S. estate tax even if they are not U.S. citizens or residents. This is because U.S. estate tax applies not only to U.S. persons, but also to non-residents who own certain U.S. assets at the time of their death.

U.S. estate tax is based on the fair market value of your U.S. assets at death, which can include U.S. real estate, shares of U.S. corporations, and certain other U.S.-situated property. The tax rate can be significant, and unlike Canadian taxes, it applies to the gross value of the property, not just the gain.

While Canada and the U.S. have a tax treaty that provides some relief — including exemptions and credits that may reduce or eliminate tax for smaller holdings — the rules are complex. Even modest ownership of U.S. assets may require careful planning to avoid unexpected tax liability.

Please visit our U.S. Estate Taxes for Canadians section for more information.


Please contact us if you would like to review your U.S. asset holdings and explore strategies to reduce potential U.S. estate tax exposure while protecting your wealth for your heirs.