Creating a smooth estate plan across Canada and the U.S.

How we helped a dual citizen simplify her estate and protect her daughters from cross-border tax traps.

JULIA’S STORY

Managing an estate across two countries can feel overwhelming with layers of rules, risks and tax traps. This story shows how Julia worked with Lisa to simplify cross border planning, protect her daughters from taxes, and create a legacy that honored her life’s work. For new clients it shows how smart strategies turn complexity into clarity and bring peace of mind across borders.

Situation

When Julia Mason came to see Lisa, she brought more than a balance sheet, she brought a tangle of international rules, family priorities, and a clear goal: “I want my daughters to receive as much of my estate as possible, without a tax nightmare.”

Julia was a dual citizen of Canada and the U.S., in her mid-50s and living in Toronto after two decades of success as a tech consultant. She held significant assets in both countries, including Canadian real estate, U.S. bank accounts, a family cottage in Muskoka, and retirement plans on both sides of the border.

Her two adult daughters were Canadian residents, and Julia wanted to leave them a smooth, stress-free inheritance. But she was worried. Her cross-border status put her at risk for U.S. estate taxes on her entire global estate. Left unaddressed, this could result in double taxation, probate delays, and forced sales.

Lisa knew this would require more than one smart strategy, it would take a team. And Julia would need someone she could trust to guide every step.

Process

Lisa proposed a powerful and tailored solution: an irrevocable life Insurance trust (ILIT) paired with a 20-pay universal life insurance policy. The goal? To remove assets from Julia’s estate while creating a tax-free, cross-border legacy for her daughters.


Here’s how they did it:

  • Trust Setup With the help of a Canadian estate lawyer, Lisa established an ILIT to own the policy, keeping the death benefit outside of Julia’s taxable estate.
  • Cross-Border Compliance Lisa brought in a U.S. tax attorney to ensure the trust met IRS rules as a non-grantor trust, and worked with a cross-border accountant to address ongoing reporting obligations.
  • 20-Pay Universal Life Julia made annual contributions to the trust, within allowable gift tax exemptions. The trust then paid premiums on a $3 million policy, designed to be fully paid up in 20 years.
  • Ongoing Stewardship Lisa remained the central guide, facilitating conversations, simplifying complex documents, and ensuring annual reviews kept the plan aligned with Julia’s long-term goals.

It was a sophisticated strategy, but Lisa made it feel approachable and manageable, every step of the way.

Outcome

Years later, when Julia passed away, the plan worked exactly as designed.

  • The $3 million tax-free death benefit was paid to the trust.
  • No estate taxes were triggered in Canada or the U.S.
  • The trust distributed the funds privately and efficiently to Julia’s daughters, without delays, disputes, or unexpected tax bills.

What Julia left behind wasn’t just financial security. It was clarity. It was peace of mind. It was a legacy rooted in care and built with foresight.

Lisa’s leadership ensured that Julia’s daughters inherited not just assets, but a plan that reflected their mother’s deep love and thoughtful intention.

The greatest gift of planning is knowing your family will receive your legacy with clarity and peace of mind, not confusion and complications.

Lisa

Lisa