[WSBAPT] US Canadian Dual Citizen Gift Tax Implications

[Jacob Menashe]

Carla, thank you so much. I've conferred with Garrett Beyer before and I benefited greatly from that. I appreciate his offer of my being able to call him or shoot him an email.

Best,

Jacob

From: wsbapt-bounces at lists.wsbarppt.com <wsbapt-bounces at lists.wsbarppt.com> On Behalf Of Carla J. Higginson
Sent: Monday, March 15, 2021 7:40 PM
To: WSBA Probate & Trust Listserv <wsbapt at lists.wsbarppt.com>
Cc: Garrett J. Beyer <garrett at higginsonbeyer.com>
Subject: Re: [WSBAPT] US Canadian Dual Citizen Gift Tax Implications

My law partner Garrett Beyer, who is an international tax attorney handling many matters between the US and Canada, says that from the US tax perspective, you are correct.  He says that you should feel free to give him a quick call or shoot him an email if there is anything you would like to chat about.  His email address is above.

___________________________

Carla J. Higginson, Attorney
Higginson Beyer, P.S.    [cid:image001.png at 01D71A38.223BE3C0]
Friday Harbor Office:
175 Second Street North, Friday Harbor, Washington 98250 | Telephone: (360) 378-2185 | Facsimile: (360) 378-3935
Seattle Office:
701 Fifth Avenue, Suite 5500, Seattle, Washington 98104 | Telephone: (206) 623-8888 | Facsimile: (360) 378-3935

carla at higginsonbeyer.com<mailto:carla at higginsonbeyer.com>
HigginsonBeyer.com

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From: wsbapt-bounces at lists.wsbarppt.com<mailto:wsbapt-bounces at lists.wsbarppt.com> <wsbapt-bounces at lists.wsbarppt.com<mailto:wsbapt-bounces at lists.wsbarppt.com>> On Behalf Of Jacob Menashe
Sent: Monday, March 15, 2021 5:04 PM
To: WSBA Probate & Trust Listserv <wsbapt at lists.wsbarppt.com<mailto:wsbapt at lists.wsbarppt.com>>
Subject: [WSBAPT] US Canadian Dual Citizen Gift Tax Implications


I am thinking about a US-Canadian dual citizen who resides in Canada. She may make a gift of her Washington property to a Washington resident who is also a US-Canadian dual citizen though a Washington resident. I am only thinking about this from a US tax perspective.



My take right now is: I don't think the cross border aspects change anything from a US tax perspective. In other words, my take is it's all simply as it would be if there were no Canucks involved-for instance, gift tax return required; the use of some lifetime exemption/no tax due (assuming the right facts); and a carryover basis.



Am I missing something? I will be very quick to confer with someone if it may not be as simple, from a US tax perspective, as I think it is.



Thanks,



Jacob

Jacob H. Menashe
Hickman Menashe, PS
4211 Alderwood Mall Blvd., Suite 204
Lynnwood, WA 98036
(425) 744-5658 phone
(425) 744-6078 fax
Satellite Office in Bellevue
www.hickmanmenashe.com

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