February 1, 2005 - Phil Hodgen

Canadians, vacation homes, and U.S. estate tax

The Canadian Revenue Agency has reversed a long-held administrative position and issued a ruling, effective January 1, 2005, that makes a favored real estate holding structure (ahem) completely useless for Canadian buyers of U.S. real estate. See the explanation on

Bottom line: Canadians shouldn’t use Canadian single purpose corporations to hold U.S. real estate anymore. Time to be creative. Or buy life insurance.

Nonresidents with US Activities US Real Estate Investments