U.S. trust question!

This is our main tax information forum which deals with topics concerning Canadians living and working in the U.S., U.S. citizens contemplating working in Canada, and all aspects of Canadian and U.S. income tax and related adminstrative issues.

Moderator: Mark T Serbinski CA CPA

Post Reply
rasman
Posts: 8
Joined: Sun Jul 19, 2009 11:07 pm

U.S. trust question!

Post by rasman »

I know this is complicated but here goes: I am a dual citizen (US/CDN) resident of Canada. A relative just passed away in the US-- I am one of 3 trustees of a small trust (about 800K in assets) that includes real estate. The trust will likely be split and liquidated over the next few years.

I know there's no inheritance tax in Canada but I have a few questions--

1) does the real estate become a "deemed disposition" upon the relative's death that I must pay cap gains on in Canada? If so, is it only when the property is sold?

2) If there are 3 trustees with only one living in Canada, can CCRA declare the trust a "Canadian Trust" even though it exists in US?

3) Suggestions for paying the least amount of tax if there is any...?
rasman
Posts: 8
Joined: Sun Jul 19, 2009 11:07 pm

***BUMP***

Post by rasman »

Is there anyone qualified in this field to answer?!
testone
Posts: 92
Joined: Mon Dec 01, 2008 10:05 pm

Post by testone »

I don't know the answers to your questions, as they seem to be mostly about Canadian tax law. However, you should note that from a U.S. tax perspective the trust may be considered a "foreign" trust if you as a trustee are located in Canada. If this is the case, the trust would likely have U.S. tax filing requirements -- seel Form 3520 and 3520A.
Post Reply