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 differ from those for determining residency for U.S. income taxes.
Key aspects of transfer taxes are discussed below are discussed in this Estate tax update.
