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How does the U.S.-Canada tax treaty handle estate tax for Canadian LLC owners?
I'm a Canadian citizen with a U.S. LLC that earns income from consulting services. I also have a U.S. brokerage account with about $500,000 in stocks. My worldwide estate is about $4 million. How does the U.S.-Canada treaty help with estate tax? I've heard Canada doesn't have an estate tax but instead has a deemed disposition at death. How do the two systems interact?
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Is it true non-resident aliens only get a $60,000 estate tax exemption in the U.S.?
I'm a British citizen living in London and I own a single-member LLC in Delaware that holds a rental property in Texas. A friend told me that if I die, the U.S. will tax my estate but only exempt the first $60,000 — compared to over $13 million for U.S. citizens. That seems absurdly low. Is this actually correct? What happens to my LLC and the property inside it if something happens to me?
What counts as a U.S. situs asset for NRA estate tax purposes?
I'm trying to understand my estate tax exposure as a non-resident alien. I own a U.S. LLC, have a U.S. brokerage account with stocks, a U.S. bank account, and some cryptocurrency on a U.S. exchange. Which of these are considered U.S. situs assets that would be subject to estate tax if I die? I keep seeing different lists online and I'm confused about what actually counts.
Are LLC membership interests considered U.S. situs property for estate tax?
I'm a Canadian citizen and I own a 50% membership interest in a multi-member LLC organized in Florida. The LLC operates an e-commerce business and holds some inventory in a U.S. warehouse. My partner is American. If something happens to me, would my 50% membership interest be treated as U.S. situs property subject to estate tax? I've heard that partnership interests might be treated differently than direct asset ownership.
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