Secure Your LegacyAcross Borders.
Navigating the complexityof dual-jurisdiction.
Managing an estate that spans international borders presents unique and significant legal challenges. Without proper structuring, beneficiaries may face double taxation, protracted probate periods, or the invalidation of testamentary documents in foreign courts. Our legal memorandums provide clarity and guidance on how to resolve these critical issues.
One memo. One concrete fact pattern.
Each memorandum addresses a specific cross-border scenario — not a chapter of a textbook, not a generic FAQ, not an AI-chatbot answer.
Authored by cross-border lawyers and accountants.
Drafted by practitioners in cross-border estates, and footnoted with hyperlinks to the supporting statutes, regulations, treaties, caselaw, doctrine, tax rulings and technical interpretations.
The same answer at a fraction of the cost.
Memos start at $20. An equivalent initial research as part of a private retainer typically costs $1,200–$3,500 in billable hours.
Walk into your consultation already informed.
Get up to speed on the foundational concepts and key issues before your first paid meeting with a lawyer. Skip the primer, focus the conversation on your situation, and save time and money on the eventual retainer.
Sound familiar?
A memo for
every fact pattern.
If you can describe your situation in one sentence — like the ones below — there is almost certainly a memorandum already drafted for it. If not, we’ll write one for you.
My father, a Canadian resident with US citizenship, died last month, owning a home in Vancouver and a condo in Palm Springs. I live in New York and was named the executor of his estate, but my father’s will only covers the Vancouver home. What information do I need to prepare for probate and tax filings? Will the estate become a non-resident trust for Canadian tax purposes?
I live in Vancouver but I own a condo in Florida. I’m worried about US estate tax when I die.
My aunt left me £600,000 in her London estate. The solicitor won’t remit until HMRC issues the inheritance tax (IHT) clearance. How long will that take? And do I need to report the inheritance to the CRA in Canada?
I live in Los Angeles, and my father just left me 51% of his Vancouver family company. My US accountant is warning about CFC and PFIC traps. What am I walking into, and is there any way to restructure before the estate closes?
We own a villa in Provence, France. Our notaire warned that French forced heirship overrides our BC will and locks shares to our children. Can we elect Canadian law to escape it?
My father died in Vancouver, leaving his Seoul apartment to me, and naming my mother as beneficiary of his Canadian RRIF. Korea wants to impose inheritance tax. CRA wants the deemed disposition. Does the foreign tax credit actually offset the capital gains tax in Canada?
I’m BC-resident and bought a London flat ten years ago. The Canada–UK treaty only covers income tax. Will my kids pay 40% IHT on top?
My parents in Seoul are wiring CAD 1.5M for me to buy a Vancouver home. Is this a gift or a loan — and who pays what tax, where? Are there any reporting obligations on foreign remittances?
My father died in Seoul and I live in Vancouver. The Korean bank is refusing to release the funds without a Canadian lawyer’s notarization of my identity documents and an apostille certification of the same. How do I prepare them?
“Cross-border estate questions rarely fit neatly into one country’s law. To navigate them, you need step-by-step guidance.
These memoranda are written to provide them, at a fraction of the cost.”
Featured memorandums
Concrete answers,page by page.
Commission a memorandum
Your fact pattern not yet covered?
We draft commissioned memoranda on cross-border estate and tax matters involving Canada and the United States. If your situation involves a jurisdiction or fact pattern not yet addressed in our published series, we will write a memorandum tailored to it and make it available for purchase directly from this store.