Ontario Snowbird With a $450K Florida Condo and $1.2M Canadian Estate: How US Estate Tax and Canadian Deemed Disposition Stack at Death in 2026
Key Takeaways
- 1Understanding ontario snowbird with a $450k florida condo and $1.2m canadian estate: how us estate tax and canadian deemed disposition stack at death in 2026 is crucial for financial success
- 2Professional guidance can save thousands in taxes and fees
- 3Early planning leads to better outcomes
- 4GTA residents have unique considerations for inheritance planning
- 5Taking action now prevents costly mistakes later
Quick Summary
This article covers 5 key points about key takeaways, providing essential insights for informed decision-making.
Quick Answer
If you are an Ontario resident who dies owning a $450K Florida condo (purchased for $220K) with a total worldwide estate of $1.2M, you face two tax systems simultaneously — and the one most people worry about is not the one that costs them the most. The US estate tax: under the Canada-US Tax Treaty (Article XXIX-B), your estate gets a prorated unified credit. With the 2026 US exemption at $15M per individual (raised permanently by the One Big Beautiful Bill Act), the prorated exemption for your $450K US-situs asset in a $1.2M worldwide estate is $5.625M. Your $450K condo is nowhere near that threshold. US estate tax owed: $0. The Canadian deemed disposition: under section 70(5) of the Income Tax Act, the $230K capital gain on the condo ($450K FMV minus $220K ACB) is reported on your terminal return. At the 50% inclusion rate (the full gain falls under the $250K first-tier threshold), $115K of taxable income is added to your final return. Depending on your other income, Ontario combined marginal rates of 37% to 53.53% apply to that $115K. Estimated Canadian tax on the condo gain alone: $42K to $62K. Then there is Florida ancillary probate — a separate court process required because the condo is real property in a foreign jurisdiction. Cost: typically $5K to $15K in legal fees plus Florida filing costs. Total cross-border friction on a $450K Florida condo at death: roughly $50K to $75K, almost entirely from the Canadian side.
Key Takeaways
- 1The US estate tax is almost certainly $0 for this scenario — and for most Canadian snowbirds in 2026. The One Big Beautiful Bill Act permanently raised the US federal estate tax exemption to $15M per individual ($30M per couple), effective 2026. Under the Canada-US Tax Treaty (Article XXIX-B), a Canadian resident's estate receives a prorated unified credit: the full $15M exemption multiplied by the ratio of US-situs assets to worldwide assets. For a $450K Florida condo in a $1.2M worldwide estate, the prorated exemption is $15M × ($450K / $1.2M) = $5.625M. The condo is $450K. No US estate tax. Without the treaty, non-resident aliens get only a $60,000 US exemption — which would have triggered roughly $152K in US estate tax on the $450K condo. The treaty is what saves you, and claiming it requires filing IRS Form 706-NA with the treaty election. Your executor must file this form even when no tax is owed — the treaty benefit is not automatic.
- 2Canadian deemed disposition is the real tax bill. Under section 70(5) of the Income Tax Act, you are deemed to have sold the Florida condo at fair market value immediately before death. The $230K capital gain ($450K minus $220K ACB) hits your terminal T1 return. With the post-2024 tiered inclusion, the first $250K of annual capital gains for individuals is included at 50%. Your entire $230K gain falls within this first tier — $115K of taxable income. At Ontario's combined marginal rates (anywhere from 37.91% to 53.53% depending on your other terminal-year income), the tax on the condo gain alone runs $42K to $62K. This is not optional, not deferrable (no spousal rollover on non-Canadian property held personally), and not offset by the fact that the US charged $0.
- 3Florida ancillary probate is a separate legal process that your estate cannot avoid if the condo is held personally. Ontario probate covers Ontario assets; it does not give your executor authority over Florida real property. Your estate must open an ancillary probate proceeding in the Florida county where the condo is located. Florida has no state estate tax (repealed in 2005), but the ancillary probate process typically costs $5K to $15K in US legal fees — attorney, court filings, title transfer. Timeline: 3 to 9 months, running parallel to the Ontario estate administration. The condo cannot be sold, transferred, or re-titled until Florida probate completes. This is in addition to Ontario Estate Administration Tax (probate fees) on your Canadian assets.
- 4A cross-border revocable trust or a Canadian-controlled corporation can eliminate the Florida probate exposure and may reduce US estate tax risk for larger estates. Holding the condo in a Canadian corporation has historically been the standard play — the corporation owns the condo, so at your death the US-situs asset is corporate shares (Canadian property), not Florida real estate. This avoids Florida ancillary probate entirely and removes the asset from US estate tax calculation. The trade-off: the IRS may treat the corporation as a controlled foreign corporation, the condo loses its personal-use tax treatment, and annual US tax compliance costs ($2K–$5K/year) add up. A cross-border revocable trust avoids Florida probate while keeping personal-use treatment, but triggers different US reporting obligations (Form 3520). Neither structure eliminates the Canadian deemed disposition — that follows the beneficial owner regardless of the holding structure.
- 5The foreign tax credit prevents true double taxation, but in 2026 most snowbird estates will not need it because the US tax is $0. If the US did impose estate tax — possible for Canadians with very large worldwide estates or concentrated US-situs holdings — the Canada-US Tax Treaty allows the Canadian estate to claim a foreign tax credit on the terminal return for US estate tax paid, reducing the Canadian capital gains tax on the same property. The credit mechanism works under Article XXIV of the treaty and section 126 of the Income Tax Act. The credit is limited to the Canadian tax otherwise payable on the same income. In practice, for estates under $5M worldwide, the $15M US exemption makes the foreign tax credit moot — but the mechanism matters for larger estates where the prorated exemption does not fully shelter the US-situs assets.
Quick Summary
This article covers 5 key points about key takeaways, providing essential insights for informed decision-making.
The US Estate Tax Calculation: Why Most Canadian Snowbirds Owe $0 in 2026
Start with the baseline that scares everyone: without the Canada-US Tax Treaty, non-resident aliens (which includes all Canadian citizens who are not US residents) get a US estate tax exemption of just $60,000. On a $450K Florida condo, that would leave $390K exposed to US federal estate tax at a top rate of 40% — roughly $152K in US estate tax on a property you bought as a retirement getaway. For a deeper look at how the $60,000 baseline works, see our snowbird US estate tax guide.
The treaty changes everything. Article XXIX-B of the Canada-US Tax Treaty gives Canadian residents a prorated share of the full US unified credit — the same credit available to US citizens and residents. In 2026, the full US estate tax exemption is $15M per individual ($30M per married couple), permanently raised by the One Big Beautiful Bill Act. The proration formula:
Treaty Proration Formula (Article XXIX-B)
Prorated exemption = Full US exemption × (US-situs assets ÷ Worldwide gross estate)
For our Ontario snowbird:
• Full US exemption (2026): $15,000,000
• US-situs assets: $450,000 (the Florida condo at FMV)
• Worldwide gross estate: $1,200,000
• Prorated exemption: $15,000,000 × ($450,000 / $1,200,000) = $5,625,000
The US-situs estate is $450,000. The prorated exemption is $5,625,000. The condo is sheltered by a factor of 12.5×. US estate tax: $0.
This is the part that changed dramatically in 2026. Before the One Big Beautiful Bill Act, the US exemption was $13.99M (2025) — and was scheduled to drop back to roughly $7M in 2026 under the original Tax Cuts and Jobs Act sunset. If the sunset had taken effect, the prorated exemption on our $450K condo would have been $7M × 0.375 = $2.625M — still comfortably above the $450K condo. For typical snowbird estates under $5M worldwide, the US estate tax has been a paper tiger for the last decade. The fear was always about the potential sunset, not the current math.
When US Estate Tax Actually Bites a Canadian Snowbird
The proration formula works against you when your worldwide estate is very large relative to your US holdings. If the same $450K condo sat in a $40M worldwide estate, the prorated exemption would be $15M × ($450K / $40M) = only $168,750 — and the $450K condo would trigger roughly $112K of US estate tax. The bigger your worldwide estate and the smaller your US-situs fraction, the less treaty protection you get. For estates over $10M worldwide, run the formula before assuming you are safe. For our $1.2M snowbird? Not even close to an issue.
Canadian Deemed Disposition: The Tax Bill Nobody Budgets For
While the US side produces $0, the Canadian side produces the actual bill. Under section 70(5) of the Income Tax Act, every capital property you own is deemed sold at fair market value immediately before death. This includes foreign real estate. The Florida condo is no different from an Ontario rental property or a non-registered investment account — it hits your terminal T1 return as a capital gain.
Deemed Disposition Calculation — $450K Florida Condo
| Item | Amount |
|---|---|
| Fair market value at death | $450,000 |
| Adjusted cost base (ACB) | $220,000 |
| Capital gain | $230,000 |
| Inclusion rate (gain under $250K threshold) | 50% |
| Taxable capital gain | $115,000 |
| Tax at ~44% marginal (mid-range Ontario bracket) | ~$50,000 |
The exact marginal rate depends on total income in the terminal year. If the deceased also had a $200K RRIF collapsing on the same return, the marginal rate on the condo gain could push to 48–53%. For a full breakdown of how deemed disposition works across different asset types, see our deemed disposition guide.
Two details that catch snowbirds off guard on the Canadian side:
- Currency conversion amplifies the gain. You bought the condo for US$170K when the exchange rate was ~1.30 (CAD ACB: $220K). At death, the condo is worth US$330K at an exchange rate of ~1.36 (CAD FMV: $450K). Part of your "gain" is just the Canadian dollar weakening — but the CRA does not care. The capital gain is calculated entirely in Canadian dollars, and the exchange-rate drift is taxable.
- No spousal rollover on personally-held foreign real property if only one spouse is on title. If both spouses are on title as joint tenants, the surviving spouse's half can be deferred. But many snowbird couples title the condo in one name only (often for US liability reasons), which means the full deemed disposition hits on the first death.
Which Country Gets First Claim? The Foreign Tax Credit Mechanism
When the US does charge estate tax (which it does not in our $1.2M scenario, but does for larger estates), the question becomes: do you pay full tax in both countries? No. Article XXIV of the Canada-US Tax Treaty and section 126 of the Income Tax Act provide a foreign tax credit on the Canadian terminal return for US estate tax paid on the same property.
The credit is not dollar-for-dollar in all cases. The US estate tax is calculated on the full fair market value of the property. The Canadian tax is calculated on the accrued gain (FMV minus ACB). These are different bases. A $450K condo with a $220K ACB has a $230K gain for Canadian purposes but a $450K value for US purposes. The foreign tax credit on the Canadian return is limited to the Canadian tax otherwise payable on the income arising from the same property — you cannot use excess US tax credits to offset Canadian tax on other income.
For the vast majority of Canadian snowbirds in 2026, this is academic. The US estate tax is $0 under the treaty, so the foreign tax credit does not come into play. But estate plans should account for future changes — the $15M exemption was set by legislation, and future US administrations could change it. For estates with significant US holdings, see our cross-border estate planning guide.
Florida Ancillary Probate: The Separate Court Process You Cannot Skip
If you hold the Florida condo personally (not through a corporation or trust), your estate must go through ancillary probate in Florida — a separate legal proceeding in the county where the condo is located. Your Ontario estate certificate does not give your executor authority over Florida real property. Florida is a different jurisdiction, with its own probate court, its own rules, and its own timeline.
Florida Ancillary Probate — Cost and Timeline
| Item | Typical Range |
|---|---|
| Florida attorney fees | $3,000–$10,000 |
| Court filing fees | $300–$500 |
| Title company / recording fees | $500–$2,000 |
| Publication / notice to creditors | $150–$300 |
| Total | $5,000–$15,000 |
Timeline: 3 to 9 months. Runs in parallel with Ontario estate administration. Florida has no state estate tax (repealed 2005). Florida attorney fees for ancillary probate are often calculated as a percentage of the Florida property value — Florida Statute §733.6171 provides a fee schedule, though most attorneys negotiate a flat or hourly rate for Canadian ancillary estates.
Meanwhile, on the Ontario side, your Canadian assets go through regular Ontario probate. The Ontario Estate Administration Tax applies at 1.5% on estate assets above $50K. On $750K of Canadian assets (the $1.2M estate minus the $450K condo, which is not an Ontario asset): ($750K – $50K) × $15 per $1,000 = $10,500 in Ontario probate fees. Combined with the $5K–$15K Florida ancillary cost, your estate pays $15K–$25K in probate across two jurisdictions. For the full Ontario calculation, see our Ontario probate fees guide.
Cross-Border Structures That Neutralize the Double Exposure
There are three main holding structures Canadian snowbirds use to manage the cross-border friction. None of them eliminates the Canadian deemed disposition — that follows the beneficial owner — but they can eliminate Florida probate and reduce or remove US estate tax exposure.
Structure 1: Canadian Corporation
The traditional play. You incorporate a Canadian holding company that purchases the Florida condo. At your death, you own Canadian corporate shares — not US real property. The shares are Canadian-situs for treaty purposes, so US estate tax does not apply. Florida ancillary probate is avoided because the corporation (not the deceased individual) owns the condo, and the corporation survives the shareholder's death.
The Trade-Offs Nobody Mentions in the Brochure
Personal use of a corporate-owned condo triggers a shareholder benefit under section 15(1) of the ITA — taxable to you at your marginal rate. Annual US tax compliance for the corporation runs $2K–$5K (the corporation files as a foreign entity with the IRS). The condo is subject to FIRPTA (Foreign Investment in Real Property Tax Act) withholding of 15% on the gross sale price if the corporation eventually sells. And the CRA may treat the corporation as having a deemed dividend on wind-up. For a $450K condo, the annual compliance costs over a 20-year holding period ($40K–$100K) can exceed the estate-planning benefit. This structure makes sense for condos over $750K or estates over $5M worldwide where the US estate tax risk is real.
Structure 2: Cross-Border Revocable Trust
A revocable trust (sometimes called a "living trust" or "inter vivos trust") holds title to the condo. At your death, the trust does not go through probate — it distributes according to its terms, bypassing both Ontario probate on the condo (if the trust is properly structured) and Florida ancillary probate. The trust preserves personal-use treatment on the Canadian side (the CRA treats the trust as a bare trust, with income and gains attributed back to the settlor). US reporting requirements include Form 3520 and potentially Form 3520-A — annual compliance cost of $1K–$3K.
Structure 3: Joint Tenancy With Right of Survivorship
The simplest structure. Both spouses hold the condo as joint tenants with right of survivorship (JTWROS) under Florida law. At the first death, the surviving spouse automatically inherits the deceased's half by operation of law — no probate required in Florida. On the Canadian side, the deceased is deemed to have disposed of their 50% interest, so only half the gain ($115K gain, $57.5K taxable) hits the terminal return. The other half defers to the surviving spouse's eventual death or sale.
The limitation: this only works for the first death. At the second death (when the surviving spouse dies holding 100% of the condo), the full deemed disposition and Florida ancillary probate come back. And if the couple divorces or one spouse has creditor issues, JTWROS creates exposure that a trust would not.
The Complete Tax Picture: Stacking the Canadian and US Obligations
Total Estate Costs — Ontario Snowbird, $450K Florida Condo, $1.2M Estate
| Cost Category | Amount | Jurisdiction |
|---|---|---|
| Canadian income tax on condo gain ($230K gain, 50% inclusion) | $42K–$62K | Canada (terminal T1) |
| US federal estate tax (treaty-sheltered) | $0 | United States |
| Florida state estate tax | $0 | Florida (repealed 2005) |
| Ontario probate (on $750K Canadian assets) | $10,500 | Ontario |
| Florida ancillary probate (legal + filing) | $5K–$15K | Florida |
| Total cross-border cost on the condo | $57K–$77K | Both |
Assumes no surviving spouse on title, no corporate or trust holding structure. Canadian income tax range reflects varying marginal rates depending on other terminal-year income. Additional estate costs (RRIF collapse, other deemed dispositions) are not included in this table — they are separate from the condo. For a broader view of how Canadian estates are taxed overall, see our inheritance tax guide.
Practical Checklist for Snowbirds Holding US Property Over $100K
The Cross-Border Property Checklist
1. Run the treaty proration formula now. Plug in your current US-situs FMV and worldwide estate value. If the prorated exemption is at least 3× your US-situs value, you have substantial buffer. If it is less than 2×, talk to a cross-border tax accountant.
2. Confirm your ACB in Canadian dollars. The ACB is the purchase price converted to CAD at the exchange rate on the date of purchase, plus any capital improvements (renovations, special assessments allocated to the unit). Many snowbirds have no record of the original exchange rate — find it now, not after death.
3. Review title ownership. If both spouses are on title as JTWROS, only half the gain triggers at first death and Florida ancillary probate is avoided on the first death. If only one spouse is on title, the full gain hits on one terminal return with no spousal rollover deferral.
4. Evaluate whether a holding structure makes sense. For condos under $500K in estates under $5M, the annual compliance cost of a corporation or trust usually exceeds the estate-tax savings. For larger properties or larger estates, the math shifts.
5. Ensure your executor knows about the Florida property. Ancillary probate requires a Florida attorney. If your Ontario executor does not know the condo exists — or does not have the deed, condo association documents, and US bank account details — the process stalls.
6. File IRS Form 706-NA even when US estate tax is $0. The treaty credit is claimed on this form. Without it, the IRS defaults to the $60,000 non-resident exemption — which would produce a tax bill on any condo over $60K. Your executor must affirmatively elect the treaty benefit.
7. Budget for the Canadian deemed disposition. This is the tax that actually hits. On a $230K gain, expect $42K–$62K in Canadian income tax on the terminal return. The estate needs liquidity to pay this within six months of death. Life insurance or liquid Canadian assets can bridge the gap.
Frequently Asked Questions
Q:Do Canadian snowbirds pay US estate tax on a Florida condo in 2026?
A:Most Canadian snowbirds will owe zero US estate tax in 2026. The One Big Beautiful Bill Act permanently raised the US federal estate tax exemption to $15M per individual. Under the Canada-US Tax Treaty (Article XXIX-B), Canadian estates receive a prorated unified credit based on the ratio of US-situs assets to worldwide assets. For a typical snowbird with a $300K–$600K Florida condo and a $1M–$3M worldwide estate, the prorated exemption far exceeds the value of the US property. Without the treaty, non-resident aliens receive only a $60,000 exemption — which would catch almost every snowbird condo. The treaty is what protects you, and your executor must actively claim it by filing IRS Form 706-NA.
Q:What is the Canada-US Tax Treaty unified credit proration formula?
A:The prorated unified credit equals the full US unified credit multiplied by (value of US-situs assets / value of total worldwide gross estate). In 2026, the full exemption is $15M. If your US-situs assets (the Florida condo) are $450K and your worldwide estate is $1.2M, the prorated exemption is $15M × ($450K / $1.2M) = $5.625M. Your US-situs estate of $450K is well below $5.625M, so no US estate tax is owed. The formula uses gross asset values — not net of mortgages. If the condo has a $200K mortgage, the gross value is still $450K for purposes of this calculation.
Q:How does deemed disposition work on a Florida condo owned by a Canadian?
A:Under section 70(5) of the Income Tax Act, a Canadian resident is deemed to have disposed of all capital property at fair market value immediately before death. This includes foreign real estate. The capital gain (FMV minus adjusted cost base) is reported on the deceased's terminal T1 return and taxed at Canadian rates. For a $450K condo with a $220K ACB, the deemed gain is $230K. With the 50% inclusion rate on the first $250K of gains, $115K is added to taxable income. The condo's value is converted to Canadian dollars at the exchange rate on the date of death for tax purposes.
Q:What is Florida ancillary probate and how much does it cost for Canadians?
A:Ancillary probate is a secondary probate proceeding required in Florida when a non-resident dies owning Florida real property. Your Ontario estate certificate (probate) does not give your executor legal authority over the Florida condo — a separate Florida court order is required. Costs typically run $5K to $15K in US legal fees (Florida attorney, court filings, title company fees). Timeline is 3 to 9 months. Florida has no state estate tax, so the cost is purely procedural. The condo cannot be sold, transferred to heirs, or re-titled until ancillary probate completes.
Q:Can a Canadian corporation hold a Florida condo to avoid US estate tax?
A:Yes, and this is the traditional cross-border structure for Canadian snowbirds. If a Canadian corporation owns the condo, the US-situs asset at your death is the corporate shares — which are Canadian property, not US real property. This removes the condo from US estate tax entirely and avoids Florida ancillary probate. The trade-offs: annual US tax compliance costs ($2K–$5K), potential IRS scrutiny of the corporation as a controlled foreign corporation, loss of personal-use property tax treatment on the Canadian side, and the condo may be subject to FIRPTA withholding on eventual sale. For condos under $500K, the annual compliance cost often exceeds the estate-planning benefit.
Q:Does the foreign tax credit prevent double taxation on a snowbird estate?
A:The Canada-US Tax Treaty (Article XXIV) and section 126 of the Income Tax Act allow the Canadian estate to claim a foreign tax credit for US estate tax paid, reducing the Canadian deemed-disposition tax on the same property. In 2026, most snowbird estates owe $0 in US estate tax (thanks to the $15M exemption), so the foreign tax credit is moot for typical estates. For very large estates where US estate tax does apply, the credit prevents paying full tax in both countries on the same gain — but it does not eliminate the tax entirely, because the US estate tax is based on fair market value while the Canadian tax is based on the accrued capital gain. The two taxes are calculated on different bases.
Question: Do Canadian snowbirds pay US estate tax on a Florida condo in 2026?
Answer: Most Canadian snowbirds will owe zero US estate tax in 2026. The One Big Beautiful Bill Act permanently raised the US federal estate tax exemption to $15M per individual. Under the Canada-US Tax Treaty (Article XXIX-B), Canadian estates receive a prorated unified credit based on the ratio of US-situs assets to worldwide assets. For a typical snowbird with a $300K–$600K Florida condo and a $1M–$3M worldwide estate, the prorated exemption far exceeds the value of the US property. Without the treaty, non-resident aliens receive only a $60,000 exemption — which would catch almost every snowbird condo. The treaty is what protects you, and your executor must actively claim it by filing IRS Form 706-NA.
Question: What is the Canada-US Tax Treaty unified credit proration formula?
Answer: The prorated unified credit equals the full US unified credit multiplied by (value of US-situs assets / value of total worldwide gross estate). In 2026, the full exemption is $15M. If your US-situs assets (the Florida condo) are $450K and your worldwide estate is $1.2M, the prorated exemption is $15M × ($450K / $1.2M) = $5.625M. Your US-situs estate of $450K is well below $5.625M, so no US estate tax is owed. The formula uses gross asset values — not net of mortgages. If the condo has a $200K mortgage, the gross value is still $450K for purposes of this calculation.
Question: How does deemed disposition work on a Florida condo owned by a Canadian?
Answer: Under section 70(5) of the Income Tax Act, a Canadian resident is deemed to have disposed of all capital property at fair market value immediately before death. This includes foreign real estate. The capital gain (FMV minus adjusted cost base) is reported on the deceased's terminal T1 return and taxed at Canadian rates. For a $450K condo with a $220K ACB, the deemed gain is $230K. With the 50% inclusion rate on the first $250K of gains, $115K is added to taxable income. The condo's value is converted to Canadian dollars at the exchange rate on the date of death for tax purposes.
Question: What is Florida ancillary probate and how much does it cost for Canadians?
Answer: Ancillary probate is a secondary probate proceeding required in Florida when a non-resident dies owning Florida real property. Your Ontario estate certificate (probate) does not give your executor legal authority over the Florida condo — a separate Florida court order is required. Costs typically run $5K to $15K in US legal fees (Florida attorney, court filings, title company fees). Timeline is 3 to 9 months. Florida has no state estate tax, so the cost is purely procedural. The condo cannot be sold, transferred to heirs, or re-titled until ancillary probate completes.
Question: Can a Canadian corporation hold a Florida condo to avoid US estate tax?
Answer: Yes, and this is the traditional cross-border structure for Canadian snowbirds. If a Canadian corporation owns the condo, the US-situs asset at your death is the corporate shares — which are Canadian property, not US real property. This removes the condo from US estate tax entirely and avoids Florida ancillary probate. The trade-offs: annual US tax compliance costs ($2K–$5K), potential IRS scrutiny of the corporation as a controlled foreign corporation, loss of personal-use property tax treatment on the Canadian side, and the condo may be subject to FIRPTA withholding on eventual sale. For condos under $500K, the annual compliance cost often exceeds the estate-planning benefit.
Question: Does the foreign tax credit prevent double taxation on a snowbird estate?
Answer: The Canada-US Tax Treaty (Article XXIV) and section 126 of the Income Tax Act allow the Canadian estate to claim a foreign tax credit for US estate tax paid, reducing the Canadian deemed-disposition tax on the same property. In 2026, most snowbird estates owe $0 in US estate tax (thanks to the $15M exemption), so the foreign tax credit is moot for typical estates. For very large estates where US estate tax does apply, the credit prevents paying full tax in both countries on the same gain — but it does not eliminate the tax entirely, because the US estate tax is based on fair market value while the Canadian tax is based on the accrued capital gain. The two taxes are calculated on different bases.
Related Articles
Ready to Take Control of Your Financial Future?
Get personalized inheritance planning advice from Toronto's trusted financial advisors.
Schedule Your Free Consultation