Cross-Border Life Insurance Planning: A Canadian-U.S. Case Study
Cross-border life insurance planning can present significant tax and estate planning challenges when Canadian business owners or shareholders have U.S. tax ties. Differences between Canadian and U.S. tax rules can create unintended consequences affecting life insurance proceeds, business succession planning, and the transfer of wealth across generations.
In this Conference for Advanced Life Underwriting (CALU) Report, Hodgson Russ Partner Marla Waiss and co-author Robin Goodman examine the interaction of Canadian and U.S. tax law in the context of corporate-owned life insurance and buy-sell planning. Using a case study involving a closely held Canadian business with a U.S. shareholder, they discuss estate freezes, capital dividend account planning, U.S. estate and income tax considerations, and other cross-border planning issues.