Personal Tax Planning: Cross-Border Issues and Planning Points—Foreign Trusts and Corporations

Canadians with a property ownership structure that includes non-US trusts and/or corporations who intend to become US tax residents may be subject to various income tax and information reporting requirements imposed on foreign trusts and corporations under US tax law. This article discusses several key issues to be considered prior to relocation, and suggests potential planning points to address the pertinent issues.

Publication Details

Journal
Canadian Tax Journal/Revue fiscale canadienne
Published
2025-10-01
DOI
https://doi.org/10.32721/ctj.2025.73.3.ptp
Primary Topic
Historical and Archaeological Studies
Type
article
Field-Weighted Citation Impact
0.00
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article

Personal Tax Planning: Cross-Border Issues and Planning Points—Foreign Trusts and Corporations

Canadian Tax Journal/Revue fiscale canadienne
Historical and Archaeological Studies
article

Personal Tax Planning: Cross-Border Issues and Planning Points—Foreign Trusts and Corporations

article en

Abstract

Canadians with a property ownership structure that includes non-US trusts and/or corporations who intend to become US tax residents may be subject to various income tax and information reporting requirements imposed on foreign trusts and corporations under US tax law. This article discusses several key issues to be considered prior to relocation, and suggests potential planning points to address the pertinent issues.

Canadian Tax Journal/Revue fiscale canadienneVol. 73(3)
No poverty
Openalex Percentile: Top 42%
Historical and Archaeological Studies
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Personal Tax Planning: Cross-Border Issues and Planning Points—Foreign Trusts and Corporations · Canadian Tax Journal/Revue fiscale canadienne (2025) | TGRS Research Map | TGRS