Two tax systems, one balance sheet, one family.
One family. Two tax systems. One coordinated architecture.
Cross-border families do not arrive at the architecture; they arrive at the file. The American spouse who has filed FBARs for two decades. The Canadian-resident child who carries U.S. citizenship from a hospital they have never returned to. The Florida property held in personal name. The RRSP that needs the treaty election. The U.S. estate-tax exposure on assets the family has never thought of as “U.S. assets.”
Each piece, in isolation, has been handled by capable counsel — on one side of the border, in one calendar year, against the rules of one jurisdiction. The architecture across the two systems, viewed as a single position, rarely is. What lives in the gap between the Canadian return, the U.S. return, and the treaty is where the cost of the family’s plan most often sits.
The work is to convene the cross-border view, hold the architecture against both jurisdictions and the treaty between them, and coordinate with the family’s Canadian and U.S. tax counsel rather than substitute for either.
Four reviews that live in the gap between two systems.
Each, attended to in time, is worth more than a year of treaty filings.
The U.S. citizen inside a Canadian family.
The American spouse, the dual-citizen child, the accidental-American grandchild. Investment accounts that work for a Canadian resident but trigger PFIC treatment for the U.S. filer. Education savings, RRSP, TFSA — each with its own treaty position. Composed so the architecture serves the family member, not the citizenship by accident of birthplace.
U.S.-situs assets and the U.S. estate-tax exposure.
The Florida property in personal name. The U.S. brokerage account opened in the 1990s. The U.S. shares held directly. Each one a U.S.-situs asset for estate-tax purposes, each one composable into a structure the U.S. estate tax does not reach. Reviewed against the family’s actual exposure and the treaty’s available relief.
The cross-border estate plan.
Wills that work in both jurisdictions. Trusts whose tax character does not flip when crossed against the U.S. grantor-trust rules. Beneficiary designations composed against the treaty rather than against one jurisdiction’s defaults. Reviewed in concert with Canadian and U.S. estate counsel, against the family that exists today.
The move — in either direction.
The Canadian moving to the U.S., or the American returning to Canada. Departure tax. Pre-immigration trust planning. The principal-residence step-up. The compensation, equity, and corporate structures that have to be re-papered before the move, not after. Sequenced months in advance so the calendar of the move is not also the calendar of the structural redo.
The cross-border view, then the operating rhythm of two filing seasons.
Year one is the cross-border architectural review. From there, the relationship operates on the rhythm two jurisdictions impose — both filing seasons, both estate-planning calendars, every move or status change, in concert with Canadian and U.S. tax counsel. Existing counsel on each side continues under their own mandates.
Our daughter was born in Boston during my fellowship. We came home to Toronto a year later and never thought about it again until she was twenty-two and the IRS thought about it for us. The architectural review was the first time anyone composed her position across both systems — before her first job, not after the first late-filing notice.
Eleven adjacent audiences.
Most principals belong to more than one. The architecture is composed for the family in front of us; the descriptions below are how families most often arrive.
The Founder’s Chapter
The enterprise, the estate, and the architecture, coordinated in concert.
The Liquidity Event
Approaching, mid-sale, or year one beyond the exit.
The Stewardship Chapter
Families two and three generations into the enterprise and the estate.
The Transition
Widowhood, divorce, inheritance, or the passage to the next generation.
Business Owners & Founders
The founder whose balance sheet lives inside the operating company.
Real Estate Developers & Principals
Entity-dense portfolios, refinancing cycles, and generational passage of the book.
Medical, Dental & Allied Health
Professional corporations, retained earnings, and the practice as an asset.
Legal, Accounting & Finance
Senior professionals whose own architecture is the last to which they have time to attend.
Executives & Senior Corporate Leaders
Concentrated equity, deferred compensation, and the sequencing each requires.
Technology Founders & Venture Principals
Pre- and post-exit founders, operators, and fund principals.
Women Principals & Female Heads of Household
Founders, executives, widows, and inheritors, engaged on terms of their own choosing.
Philanthropists & Family Foundations
Families for whom philanthropy has moved from line item to operating discipline.
Compose across both jurisdictions.
A family whose members, residency, or assets cross the border deserves an architecture composed across both tax systems — not one written for one, with adjustments for the other. Inquiries are read in confidence and answered within one business day.