With anticipated policy changes to inheritance tax laws in 2025, Canadians living in the U.S. and Americans living in Canada could face new challenges and opportunities when receiving inheritances from family members in the other country. Tax implications on cross-border inheritances are a critical consideration for expats who may be subject to both U.S. and Canadian tax policies. Kris Rossignoli, Cross-Border Tax and Financial Planner at Cardinal Point Wealth Management, offers insights into how Canadian and American expats can prepare for these upcoming changes and ensure their inheritance planning is tax-efficient.
“As we approach 2025, cross-border tax planning for inheritances is taking on new urgency,” says Kris Rossignoli. “With shifting policies expected in both the U.S. and Canada, it’s more important than ever for Americans living in Canada and Canadians living in the U.S. to understand how inheritance tax laws could impact their financial planning.”
Impact of Inheritance Tax Law Changes on Cross-Border Families
Cross-border tax planning experts suggest that new legislation under consideration in both countries could change how inheritances are taxed, with more stringent reporting requirements and potentially higher taxes on foreign assets and inheritances. While each country has historically provided exemptions for inheritances received from family members, forthcoming adjustments may affect the current tax landscape, especially for high-value estates.
“One of the most significant factors in cross-border inheritance planning is understanding how each country treats foreign assets,” Rossignoli explains. “For instance, if an American expat in Canada inherits assets from a U.S. family member, U.S. estate taxes may still apply, but the Canadian government may also consider this income. We could see Canada impose stricter reporting and tax obligations, requiring expats to account for these assets more thoroughly.”
For Canadian expats living in the U.S., the situation is similar but with nuances in estate and inheritance tax. The U.S. currently has a high estate tax exemption threshold, but some policymakers have called for this to be lowered, which could impact Canadians who inherit significant wealth from U.S. family members.
“Americans living in Canada or Canadians living in the U.S. who are positioned to receive large inheritances need to watch this space closely,” Rossignoli advises. “A reduced estate tax exemption in the U.S., for example, could mean higher taxes on cross-border inheritances, so advance planning is essential.”
Planning Strategies for Cross-Border Inheritances
Rossignoli advises cross-border families to explore various tax mitigation strategies before any inheritance is transferred. Working with a cross-border tax planning expert can help expats take advantage of legal structures to minimize tax exposure, such as trusts, gifting strategies, and structured distributions.
“Establishing a trust can be a valuable tool in cross-border inheritance planning,” Rossignoli says. “Trusts can provide significant tax advantages and ensure that assets pass to heirs more smoothly, without the complications of probate across jurisdictions. For Canadian or American expats with family members in both countries, a trust-based approach may help reduce the risk of double taxation.”
Additionally, families should stay informed about annual changes to reporting requirements under the Foreign Bank Account Reporting (FBAR) and Foreign Account Tax Compliance Act (FATCA) in the U.S., as these regulations often impact expats holding foreign accounts or assets. “For Americans living in Canada, it’s crucial to be diligent about reporting any financial accounts or assets held in Canada, as failure to comply with FBAR and FATCA can lead to severe penalties,” Rossignoli adds.
Monitoring Policy Developments and Seeking Professional Guidance
Cross-border financial planning is inherently complex, especially when it involves inheritance taxes. With both Canada and the U.S. reviewing tax policies for 2025, Canadian and American expats should be proactive in their planning and seek professional guidance to navigate these evolving regulations. Cardinal Point Wealth Management specializes in cross-border financial planning, offering tailored advice for expats navigating the intricate world of cross-border inheritances.
“With the potential for increased tax burdens on inheritances and a renewed focus on compliance, cross-border expats need a comprehensive tax strategy,” Rossignoli emphasizes. “By collaborating with a cross-border financial advisor, Canadians living in the U.S. and Americans living in Canada can ensure their inheritance is handled in the most tax-efficient way possible.”
About Cardinal Point Wealth Management
Cardinal Point Wealth Management is a cross-border wealth management firm specializing in providing tailored tax, estate, and financial planning services for Canadian and American expats. With offices in Canada and the U.S., Cardinal Point offers comprehensive cross-border financial planning to clients with assets and family in both countries, focusing on tax optimization, retirement planning, and compliance with cross-border regulations. The firm’s experienced advisors work to protect client wealth and ensure seamless cross-border financial management.
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Company Name: Cardinal Point Wealth Management
Contact Person: Kris Rossignoli
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Phone: 8662132036
Address:2255 Glades Road, Suite 324A
City: Boca Raton
State: FL 33431
Country: United States
Website: https://cardinalpointwealth.com/
