treatment of assets, capital gains once Canadian PR

[TLchap]

I am an American citizen looking to apply for Canadian PR status and move from the U.S. to Canada later this year with my Canadian common-law partner. I currently have a house (primary residence) in the U.S., U.S.-based retirement savings (401k, annuity, Roth IRA) and regular investments (primarily mutual funds, most of which are held in a Fidelity brokerage acct). The house and the bulk of my non-retirement assets are in a revocable trust established years ago with my American (now-deceased) spouse. I intend to maintain my U.S. citizenship and hold out the possibility of future life/work on both sides of the border, over the long term.

1) If I become a Canadian PR and am eventually comparably employed in Canada, are there significant (CRA + IRS) tax obligations (aside from generally higher/provincial income tax rates) above and beyond what I would owe in the U.S. as solely an American citizen? I.e. for capital gains on the investments (including those held in the trust), primary residence (which I might sell or rent out - haven't yet decided), a possible future inheritance, or in the eventual post-mortem disposition of my estate.

2) What would the cross-border tax consequences be of buying real estate (for a primary residence) in Canada? And what difference would it make, if any, if my partner and I buy/own such property together?

3) If things don't work out for us in Canada and I relinquish my Canadian residency before the 60-month mark that would trigger departure tax, what are the added obligations/costs/penalties, if any, that I should anticipate?

My understanding is that in general the tax treaty limits my tax liability to the higher rate between the two countries, since foreign tax credits compensate for any double taxation. At the same time I understand some kinds of assets and income are treated differently by the two tax authorities, and I don't want any nasty or avoidable $ surprises. Answers to any of the above will help allay some of my anxieties.

Thanks in advance.

[nelsona]

I won't touch the trust issue, you should see a pro about that, but
1. Asa Cdn resident, you will report world income in both US and Canada, so expect higher taxes.
2. There are no consequences; once you live in Canada you are a Cdn tax resident/
3. You would actually benefit if you left before 60 months, as you would not be subject to deemed disposition on any holdings you had when you arrived in Canada; after 60 months, deemed diposition would occur on all your holdings (the trust may be another matter)

[TLchap]

Thank you!

Any recommendations for someone who can advise about the trust question, or where to look/what kind of pro to seek?