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Do U.S. estate taxes apply to Canadians?

Updated: September 04, 2025

Canadians who own U.S. situs property, which includes both real property and U.S. marketable securities amongst other assets, will be subject to the U.S. estate tax regime on their death. While U.S. citizens, including those who live in Canada, are also subject to U.S. estate tax, the rules apply differently to U.S. citizens.

When a Canadian—who is resident of Canada at the time of death—dies owning U.S. property, their executors will find themselves dealing with a possible U.S. estate tax filing as well as the Canadian tax consequences that apply on death. Where the person who died owned worldwide assets at the time of death with a value of more than approximately $14,000,000 (U.S.) (increased to $15,000,000, for deaths in 2026), a U.S. tax bill could result.

Our guide U.S. estate tax Issues for Canadians provides more detail as to how the U.S. estate tax applies and issues for Canadians to consider. Please reach out with any questions.

Jason Ubeika
Partner, Expatriate Tax
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Joanne Sun
Partner, Expatriate Tax
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The information in this publication is current as of August 20, 2025.

This publication has been carefully prepared, but it has been written in general terms and should be seen as broad guidance only. The publication cannot be relied upon to cover specific situations and you should not act, or refrain from acting, upon the information contained therein without obtaining specific professional advice. Please contact BDO Canada LLP to discuss these matters in the context of your particular circumstances. BDO Canada LLP, its partners, employees and agents do not accept or assume any liability or duty of care for any loss arising from any action taken or not taken by anyone in reliance on the information in this publication or for any decision based on it.