A Canadian individual who is transferred to the United States may be exposed to U.S. estate, gift, or generation-skipping transfer tax (collectively, transfer taxes). The exposure depends on whether the individual is regarded for transfer tax purposes as a U.S. resident or a non-resident alien. Criteria for determining residency for U.S. transfer taxes are different from those used for determining residency for U.S. income taxes.
Key aspects of transfer taxes are discussed in the PDF below.