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Tuesday 27 October 2026 23:17:34 GMT
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CANADA VS THE US: WHO PAYS MORE TAX WHEN YOU DIE? Canada doesn't have an estate tax like the US. We tax death a different way, and it reaches a lot more regular families. Take 2 cousins. Doug in Regina and Chad in Dallas each put $2 million into index funds, and today each pile is worth $10 million. Chad's playbook is buy, borrow, die. He never sells, borrows against his shares to live, and when he dies the US resets the cost of those shares to their value that day. The $8 million of growth is never taxed, and the US federal estate tax only starts above US$15 million a person. The US Treasury puts that reset at about US$40 billion this year. Canada dropped its estate tax in 1972 and started taxing gains at death. Doug is treated as if he sold everything the day before he died. Half the gain counts, and at Saskatchewan's top rate that's about $1.87 million. In St. John's it's about $2.14 million. Probate adds about $70,000 in Saskatchewan, $149,000 in Ontario and $169,000 in Nova Scotia. Manitoba dropped its fee in 2020. A spouse defers it all, and the family home is exempt. Far past US$15 million, the US takes 40% of every dollar over the line. Big US estates paid about 19% of their value, about the same as Doug. 4 things I'd keep 1. Use your TFSA and name your spouse as successor holder, or a beneficiary. In Quebec, do it in your will. 2. Draw your RRSP or RRIF down in lower income years. A $1 million RRIF left to your kids adds about $475,000 of tax. 3. Keep your will, beneficiaries and power of attorney up to date. 4. Enjoy your retirement first, then give cash while you're alive. Canada has no gift tax on cash. Pitched life insurance or a family trust to cut the bill? Ask what it costs and who it's built for. My estate guides are in my community at calmmoneycoach.com, and my email list is free. I'm Brian Orlando, CPA, in Halifax. Advice-only planning through Calm Money Coach. No products, no commissions. US: IRS and US Treasury, read October 2026. Canada: 2026 top rates and each province's probate schedule. OECD 2018. Parliament Hill photo: Saffron Blaze, CC BY-SA 3.0. Education only. #estateplanning #estatetax #tax #personalfinancecanada
CANADA VS THE US: WHO PAYS MORE TAX WHEN YOU DIE? Canada doesn't have an estate tax like the US. We tax death a different way, and it reaches a lot more regular families. Take 2 cousins. Doug in Regina and Chad in Dallas each put $2 million into index funds, and today each pile is worth $10 million. Chad's playbook is buy, borrow, die. He never sells, borrows against his shares to live, and when he dies the US resets the cost of those shares to their value that day. The $8 million of growth is never taxed, and the US federal estate tax only starts above US$15 million a person. The US Treasury puts that reset at about US$40 billion this year. Canada dropped its estate tax in 1972 and started taxing gains at death. Doug is treated as if he sold everything the day before he died. Half the gain counts, and at Saskatchewan's top rate that's about $1.87 million. In St. John's it's about $2.14 million. Probate adds about $70,000 in Saskatchewan, $149,000 in Ontario and $169,000 in Nova Scotia. Manitoba dropped its fee in 2020. A spouse defers it all, and the family home is exempt. Far past US$15 million, the US takes 40% of every dollar over the line. Big US estates paid about 19% of their value, about the same as Doug. 4 things I'd keep 1. Use your TFSA and name your spouse as successor holder, or a beneficiary. In Quebec, do it in your will. 2. Draw your RRSP or RRIF down in lower income years. A $1 million RRIF left to your kids adds about $475,000 of tax. 3. Keep your will, beneficiaries and power of attorney up to date. 4. Enjoy your retirement first, then give cash while you're alive. Canada has no gift tax on cash. Pitched life insurance or a family trust to cut the bill? Ask what it costs and who it's built for. My estate guides are in my community at calmmoneycoach.com, and my email list is free. I'm Brian Orlando, CPA, in Halifax. Advice-only planning through Calm Money Coach. No products, no commissions. US: IRS and US Treasury, read October 2026. Canada: 2026 top rates and each province's probate schedule. OECD 2018. Parliament Hill photo: Saffron Blaze, CC BY-SA 3.0. Education only. #estateplanning #estatetax #tax #personalfinancecanada

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