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April 15, 2025 20 mins

In this episode, host Gerry Scott is joined once again by Aaron Dawes, a cross-border tax specialist with Smythe LLP, for Part 2 of their discussion on estate planning across the U.S.-Canada border.

This conversation dives into the complexities that arise when Canadian children inherit assets from American parents—a growing issue in cross-border wealth management. Aaron breaks down the tax implications, planning considerations, and often-overlooked pitfalls families face when navigating real estate, IRAs, cash inheritances, and U.S. estate tax rules. He also emphasizes the critical role of cross-border tax advisors and estate lawyers in avoiding delays, penalties, or double taxation.

👉 If you haven’t already, check out Part 1 for the U.S. perspective on cross-border inheritance and key foundational insights.

What You’ll Learn in Part 2:

  • How U.S. estate tax applies to high-net-worth individuals

  • The benefits of inherited IRAs vs. lump-sum distributions

  • When and how cross-border tax treaties come into play

  • Why cash is easy but real estate can be tricky to inherit across borders

  • How late filings can result in steep penalties

  • The importance of having cross-border professionals on your estate planning team

  • How family dynamics can complicate even the best-laid plans

This is an essential listen for anyone managing assets across borders, navigating family inheritance, or helping clients prepare for a smooth generational transfer.

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