Succession begins long before ownership changes hands.
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Understanding U.S. Assets and Estate Tax
Understand what crosses the U.S. estate-tax boundary before your wealth does.
Identify which assets cross the U.S. estate tax boundary before the estate must act.
Canadians can own U.S. assets without living in the United States. Some of those assets may still create a U.S. estate tax return, tax exposure, or a delay in transferring the asset after death.
We help identify the assets that need review and organize the ownership, value, tax, filing, treaty, and available-money questions for qualified advisers.
Peter J. Merrick, TEP, leads every plan. He sees how the family, business, and estate fit together. We bring in independent experts when needed.
Who We Help
Canadians who own or may buy U.S. real estate, company shares, private investments, or other U.S. property.
Families with U.S. accounts, businesses, insurance, annuities, trusts, or beneficiaries.
Executors who may have to value, report, or transfer U.S. assets after death.
Families considering a move, sale, change in ownership, or new cross-border investment.
What We Help You Work Through
List each U.S. asset, its owner, location, value, income, debt, and named beneficiary.
Identify which assets may be treated as located in the United States for estate tax purposes.
Separate a filing requirement from the final amount of tax that may be due.
Review the possible role of treaty relief, credits, insurance, ownership, or a planned sale.
Send the final legal and tax questions to qualified Canadian and U.S. professionals.
U.S.-Located for Tax Does Not Mean Only Real Estate
The legal term U.S.-situs generally means an asset treated as located in the United States for a tax rule. U.S. real estate and shares of some U.S. companies are common examples that may need review.
Other assets may receive different treatment. The name or location of the account alone does not decide the answer.
Map the Asset, Not Just the Account
One account can hold assets with different tax treatment. A family may also own property through a company, trust, partnership, or another legal structure.
We list the asset, owner, legal form, value, debt, income, and future plan. Qualified advisers then confirm the result.
Filing and Tax Are Different Questions
An estate may have to file a U.S. return even when treaty relief, credits, deductions, or the size of the worldwide estate reduces or removes the final tax.
Planning must address both questions. Ignoring a filing duty can delay access to an asset and create added cost for the estate.
Plan Before You Buy, Move, or Sell
The best time to examine a U.S. asset is before buying it, changing ownership, moving countries, selling a business, or changing residence.
Once the facts are fixed, fewer choices may remain. A change should not be made until legal, tax, financing, insurance, and investment effects have been reviewed.
What a Stronger Position Looks Like
You know which U.S. assets require review, what facts the advisers need, whether filing and tax are separate issues, and which decisions should be made before ownership changes.
What Happens Next
Start with a confidential conversation. Tell us what you own, what is changing, and where you need greater clarity.
Organize the whole picture. We identify the key facts, gaps, risks, and decisions that need attention.
Set the next steps. We put the work in the right order. We bring in legal, tax, insurance, and investment experts when needed.
When this decision needs a broader Asset Security review, Peter can introduce you to Adrian C. Spitters at PFC Wealth Solutions™.
Each practice is responsible for its own services, agreements and applicable disclosures. Any referral arrangement and compensation are disclosed where applicable. View relationship disclosures
Continue the Research
These resources provide more background for readers who want to go deeper.
Articles and Video Briefings
U.S./Canada Cross-Border Living Can Be a Taxing Pain - introduces the practical tax and estate friction of cross-border ownership
Wealth Architecture and the Discipline of Continuity - connects asset location with family continuity
One Policy, Zero Estate Taxes, Full Legacy - explores the narrow role insurance may play within a larger estate strategy
Frameworks and Planning Tools
Owning Assets in Order of Asset Security™ - tests what must keep working for an owner to retain control
The Liquidity Gap™ - measures whether tax and estate obligations can be met without forced action
The Five Pillars of Asset Security™ - places jurisdiction and continuity inside a complete ownership framework
White Papers
Last Asset Standing™ - examines how custody and digital dependency can change the practical meaning of ownership
Explore the complete Reset Report library: Research | Frameworks | White Papers
Why Work With Us
We do not label every U.S. asset the same way. Peter helps identify the asset, owner, purpose, and family facts, then brings the correct Canadian and U.S. advisers into the review.
Frequently Asked Questions
Question 1: Does owning U.S. shares mean the estate will owe U.S. estate tax?
Not always. Asset type, ownership, value, worldwide estate, treaty relief, deductions, and credits may affect the result. A filing duty and tax owing are also separate questions.
Question 2: What does U.S.-situs mean?
It is a legal term for property treated as located in the United States for a specific tax rule. The answer depends on the type of asset and the rule being applied.
Question 3: Can we avoid the issue by moving the asset to another account?
Not necessarily. The legal asset and its ownership often matter more than the name or location of the account. Review the change before moving or selling anything.
Question 4: Can life insurance solve the estate tax problem?
Insurance may provide money for a known need, but it does not change every tax or filing rule. The policy, ownership, cost, and cross-border treatment need separate advice.
Take the Next Step
If you own or are considering U.S. property, shares, a business interest, insurance, an annuity, or another U.S. asset, we can begin with a clear asset map.
If you want to keep learning, subscribe to the weekly Reset Report. It covers ownership, cash, succession, insurance, cross-border plans, and family wealth. Each subscriber also receives a free digital copy of The King of Main Street.
Peter J. Merrick
Cross-Border, Estate and Insurance Planning
Peter J. Merrick provides estate, succession, cross-border and insurance planning only in the applicable disclosed capacity and jurisdiction.
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Peter J. Merrick’s role in any Axcess Capital Advisors Inc. relationship is referral-only. He is not an Axcess Dealing Representative and does not provide registration-dependent securities advice. Any securities or portfolio-management services are provided by the responsible registered person or independent portfolio manager under separate agreements.
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Direct precious-metals introductions may be made through Peter J. Merrick to New World Precious Metals under a separately disclosed referral arrangement.
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