Michael Cirone

Canada/U.S. Cross-border Tax, Trust and Estate Planning Lawyer

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:

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


New York University School of Law, LL.M. (U.S. Taxation), 2003
Syracuse University School of Law, J.D. (Cum Laude), 2001
University of Toronto, Hon.B.A. (with Distinction status), 1996

CPA In-depth Tax Course – Parts I and II

Member, Estate Planning Council of Canada