Altro is fast to emphasise with these purchasers that their US standing will drive the planning. He notes that US residents in Canada have ‘the worst of each worlds’ by way of tax standing, as a result of the US taxes on citizenship whereas Canada taxes on residency. Canadian taxes paid ought to produce a credit score for the upper price of Canadian tax that the US IRS will settle for. Nevertheless, ‘ought to’ and ‘will’ have completely different meanings and Altro says these conditions don’t often work out as cleanly as they should.
There are additionally loads of rookie errors advisors could make round funding administration for US citizen purchasers in Canada. Organising and maxing out a TFSA for Canadian purchasers is a no brainer, but when that shopper is a US citizen Altro notes that they might be topic to a really complicated tax submitting and US tax to pay on revenue inside a supposed tax free account.
As some purchasers angle to go away the US within the case of the election final result, Altro additionally cautions them towards any rash choices which will compromise their US standing. A Canadian citizen with a inexperienced card, for instance, might lose that inexperienced card in the event that they transfer away. Given how difficult it’s to acquire that standing, Altro typically generally recommends securing US citizenship if doable earlier than considering a transfer.
That isn’t to say all of the cross-border site visitors is a method. Whether or not pushed by higher job prospects within the US, a extra optimistic view of its politics, or the upper tax charges — each for revenue and capital features — right here in Canada, Altro is seeing lots of his purchasers push to maneuver south of the border. The upcoming election performs a key function in these choices. Given Trump’s avowed anti-immigration stance and previous historical past of utilizing government orders to sluggish the speed of US immigration, Altro is encouraging these purchasers who need to get hold of US standing to maneuver rapidly and get on that path now in case Trump wins and snarls up the system once more.
A variety of Trump’s tax cuts from his first time period, too, are on target to sundown in 2026 similar to decrease private revenue tax charges. Maybe most notably, the Trump-era doubling of the US property tax exemption could be very prone to sundown and could also be laborious to re-establish in regulation regardless of who wins in November. The present exemption price of $13 million per particular person or $26 million per couple might fall to round $7 million in 2026. In anticipation of this transformation, Altro is working with property attorneys to develop methods round gifting as much as the exemption whereas it stays excessive.
