Michael Cirone

Article | How U.S. Citizens Living In Canada Can Sell A Principal Residence And Avoid U.S. Capital Gains Tax
Article | 2020 and Beyond Brings Canada/U.S. Cross-Border Personal Tax and Estate Planning to the Forefront
Interview | Tips, Tricks & Traps in Canada/U.S. Cross-Border Tax and Estate Planning
Interview | Leaving the USA? Watch this first…

Michael is a senior Canadian and U.S. licensed lawyer who practices exclusively in the area of Canada/U.S. cross-border personal tax, trust and estate planning for Canadians with U.S. connections.

Practice Areas:

Canada/U.S. Cross-border Estate Planning

• Preparation of Cross-border Estate Plans, Cross-border Wills and Spousal Bypass Trusts/Dynasty Trusts to protect against U.S. estate tax, division of assets upon marital breakdown and third party creditors for:
  • • • U.S. citizens married to Canadians;
      • Canadian parents with U.S. citizen or U.S. resident children;
      • Canadians with U.S. assets; and
      • U.S. residents with Canadian assets.
• Preparation of Cross-border Alter Ego Trusts and Joint Partner Trusts for U.S. citizens living in Canada who are 65 years and older.

Canada/U.S. Tax Planning for Cross-border Inheritances

• Cross-border tax planning for Canadians inheriting from a U.S. resident.
• Cross-border tax planning for U.S. residents inheriting from a Canadian resident.

Lifetime Gifting Strategies for U.S. Citizens and U.S. Green Card Holders Living in Canada

• Planning and implementation of lifetime gifting strategies for U.S. citizens and U.S. green card holders living in Canada to minimize/eliminate U.S. income tax on the sale of a Canadian principal residence.

Moving from the U.S. to Canada

• Tax and estate planning for U.S. citizens/U.S. green card holders moving from the U.S. to Canada, including:
  • • • Renouncing U.S. citizenship;
      • Relinquishing U.S. green cards;
      • Minimizing or avoiding the U.S. exit tax and covered expatriate status;
      • Pre-Canadian tax residency tax planning; and
      • Restructuring U.S. assets (LLCs, U.S. revocable living trusts, U.S. non-registered investment accounts, U.S. retirement accounts) to maximize tax-efficiency once in Canada.

Purchase of U.S. Real Estate by Canadians

• Cross-border tax planning, U.S. estate tax minimization planning, liability protection planning, U.S. state probate tax minimization planning and set up of Canada/U.S. cross-border trust, limited partnership and corporate  structures for the purchase of U.S. real estate (vacation and rental) by high-net-worth Canadians.

Bar Memberships:

Ontario
New Jersey
Law Society of Ontario – FLC License to provide U.S. legal advice in Ontario