Estate planning is complicated for any family, but U.S. citizens living in Canada face unique challenges. Unlike Canada, which taxes capital gains at death, the United States imposes an estate tax based on total asset value. With the current exemption at its highest level in history but set to fall in 2026, many Americans in Canada may face significant exposure. Cross-border property ownership and high-value estates require careful planning to avoid double taxation or compliance issues. At Bordera Tax and Immigration Law, we help clients protect their assets, reduce risk, and plan confidently for the future. Whether you live in Calgary, Vancouver, or anywhere across Canada, contact us for expert cross-border estate guidance.
For U.S. citizens in Canada, estate planning must account for two very different systems. Canada treats death as a deemed sale, taxing the gain on assets. The U.S., on the other hand, imposes an estate tax based on the total value of the estate. While the U.S. exemption is currently about $13.5 million USD, it is set to drop to roughly $5–6 million in 2026. This upcoming change means many high-net-worth families could be caught off guard. Without the right strategies, heirs may face unnecessary tax bills, and estates may become entangled in two sets of reporting requirements.
Today’s estate tax exemption is historically high, protecting many families from exposure. However, when the exemption reverts in 2026, more estates will fall into taxable territory. For U.S. citizens in Canada with property or investments that push their net worth into the $10 million+ range, planning is no longer optional. Coordinating estate plans with both IRS and CRA rules is essential to avoid tax inefficiencies.
Real estate is one of the biggest challenges in cross-border planning. A Canadian home may be exempt from capital gains tax at death, but the U.S. could still assess estate tax on its value. Similarly, U.S. property owned by a Canadian resident can create complex reporting obligations and tax liabilities. These issues become even more complicated for families with multiple properties or vacation homes.
Cross-border families can benefit from tailored strategies, including the use of trusts, corporate structures, and coordinated wills. Professional advice ensures that these tools are compliant in both jurisdictions. Timing of gifts, ownership arrangements, and insurance planning can also play a role in reducing exposure. What works for Canadian-only estates may not be effective for U.S. citizens, making customized planning essential.
The window before 2026 presents an opportunity. U.S. citizens with estates that could exceed the future exemption may want to act now, before thresholds fall. Proactive planning can lock in tax benefits and create peace of mind. Waiting too long could mean facing higher estate taxes, more complicated filings, and fewer options for mitigation.
Estate planning for U.S. citizens in Canada is not a one-size-fits-all process. Every family has unique assets, goals, and cross-border ties that must be addressed carefully. At Bordera Tax and Immigration Law, we specialize in creating strategies that align with both Canadian and U.S. requirements, helping families protect wealth and simplify succession. If you own property in Canada or the United States, or if your estate may be impacted by the 2026 exemption change, now is the time to act. Contact us today to ensure your estate plan preserves your legacy without unnecessary risk or tax exposure.
Canada taxes capital gains at death, while the U.S. taxes the estate’s total value. Contact Bordera Tax and Immigration Law today to receive help with navigating the differing taxation laws.
It is about $13.5 million USD but is set to drop to around $5–6 million in 2026.
High-net-worth U.S. citizens in Canada with estates exceeding the exemption threshold.
Bordera Tax and Immigration Law is a premier firm with a focused approach to cross-border tax matters for individuals, corporations, partnerships, and trusts. With offices in Calgary and Edmonton, and in association with Kevin Kirkpatrick Professional Corporation, our team of US lawyers and accountants assists clients worldwide with renouncing US citizenship, securing US visas, and expanding Canadian businesses into the United States.
We specialize in voluntary disclosures, tax compliance, and resolving disputes with both US and Canadian tax authorities. Our deep experience with cross-border estates, trusts, and real estate investments allows us to optimize tax efficiency and safeguard client assets. We also provide expert guidance on Canadian departure tax planning.
Trusted by accounting firms, private wealth managers, and financial institutions, we are frequently invited to present on cross-border tax issues. Rely on Bordera Tax and Immigration Law for exceptional service and trusted cross-border expertise.
