U.S. estate tax is not only a hot topic in the states, but also in Canada. Canadians that own U.S. real property could be facing U.S. estate tax consequences. However, there may be some relief for these property owners under the Canada-U.S. Tax Treaty, which provides a prorated exemption amount based on the amount of U.S. owned property and overall assets. The treaty may also allow for a tax credit towards Canadian or U.S. income tax for the amount paid in U.S. estate tax.
See Samantha Prasad, Canada: How Snowbirds Can Avoid U.S. Estate-Tax Traps, Mondaq, Apr. 10, 2015.
Special thanks to Jim Hillhouse for bringing this article to my attention.
