Cross-Border Tax and Estate Planning— STEP Canada-USA 2024 Conference

Attorney Rebecca Tunney is serving as a program committee member for the STEP Canada-USA 2024 Conference and will moderate a panel on October 7 focused on cross-border tax and estate planning for Canadians with US connections and Americans with Canadian Connections.

Residents of Canada or the United States who have connections, such as beneficiaries or investments, in the other jurisdiction face unique tax and estate planning challenges. This session will present an overview of these challenges and discuss considerations and strategies for tackling them. Topics covered will include:

• Canadian estate planning and taxation on transfers, and US gift and estate tax
• Canadian estate freeze transactions
  • Structuring considerations
  • US tax considerations
• Planning alternatives: US beneficiaries of Canadian trusts
  • CFC/PFIC and GILTI issues
• Canadian departure tax and pre-immigration planning into the United States
• Planning for immigration to Canada from the United States
• US shareholders of Canadian corporations