If you have a family member who is involved in a Canadian family-owned business and is:
traditional Canadian wills and estate and tax planning may not be effective and could result in significant additional tax. This is the case even if you are not a US citizen.
If you implemented an estate freeze, some or all of the growth in the value of your company accrues for the benefit of your family. This is usually achieved by having your spouse and children own shares of your company, either directly or through a family trust.
However, if any of these family members is or becomes a US citizen or resident, you may be faced with the following tax consequences: