The High-Net-Worth Couple Considering a Move to the US
By Bryant Andrus
Profile: The High-Net-Worth Couple Considering a Move to the US
TL;DR
- January 1 brought a permanent $15 million US estate tax exemption, the 1% remittance tax on cash-funded transfers and the countdown to the July 1 CUSMA joint review.
- A 50% inclusion rate, a $1.275 million LCGE, a record US exemption and tariff pressure on some Canadian business valuations make this an unusual window for couples considering a US move.
- Pre-exit planning and getting the immigration and tax sequence right are where most of the value is, and mistakes are costly to fix after the move.
If you and your spouse are Canadian residents who have been seriously discussing a move to the United States — whether for business, family, tax, or lifestyle reasons — January 2026 may be the most favorable planning environment you’ll see for a long time. Several forces have aligned simultaneously that, taken together, make the window genuinely unusual.
Three things changed at midnight on January 1. The US estate tax exemption rose to $15 million per person — $30 million for a married couple using portability (for a spouse who isn’t yet a US citizen, the marital deduction generally requires a QDOT) — with no scheduled sunset and inflation indexing after 2026, under the One Big Beautiful Bill. The 1% remittance tax on cash-funded transfers took effect, though wires from US bank accounts and US-issued card transfers are exempt, so most planned moves of money from the US to Canada are unaffected. And the CUSMA joint review is now six months out: the parties meet on July 1 to confirm in writing whether to extend the agreement for another 16 years.
Why the Window Is Open
Canada’s capital gains inclusion rate remains at 50% — the proposed increase to two-thirds was cancelled in March 2025. The LCGE is $1.275 million for 2026 for qualifying small business shares. The US estate tax exemption is at a historic high. Tariff pressure has pushed valuations lower for many trade-exposed Canadian private businesses. For a couple considering a US move, the combination of a lower departure tax calculation, a higher destination-country exemption, and tariff pressure on some business values creates a planning environment that simply doesn’t exist in most years.
Pre-exit planning — the work done before you establish US domicile — is where the real money is. Once you’re a US resident, your worldwide estate is in the US estate tax net, your RRSP is subject to annual US reporting, and your Canadian private-company shares are potentially CFCs triggering US anti-deferral rules (and the company will generally lose CCPC status once you are non-resident). None of that is fatal to the move, but all of it is more expensive to fix after the fact than before.
The Sequence Matters Enormously
The most common and costly mistake cross-border movers make is getting the immigration and tax sequence wrong. Establishing US immigration status before completing a Canadian estate freeze, a corporate capital strip, or a spousal asset transfer can trigger immediate US tax consequences on transactions that would have been tax-free in Canada. The planning must come before the move, not after.
Ready to Talk?
Cross-border planning is time-sensitive and highly fact-specific. If any of the topics in this issue apply to your situation, we would welcome the conversation. State Bird Corp specializes in US–Canada cross-border tax, estate, and immigration planning for families and businesses on both sides of the border. Our team works with clients across the US and Canada — wherever your cross-border life takes you.
Sources
- https://rsmus.com/insights/tax-alerts/2025/irs-grants-limited-relief-from-penalties.html
- https://www.canada.ca/en/revenue-agency/services/tax/individuals/frequently-asked-questions-individuals/adjustment-personal-income-tax-benefit-amounts.html
- https://www.pm.gc.ca/en/news/news-releases/2025/03/21/prime-minister-mark-carney-cancels-proposed-capital-gains-tax-increase
- https://global.morningstar.com/en-ca/markets/canadas-stock-market-hit-historic-highs-2025
- https://www.mccarthy.ca/en/insights/blogs/terms-trade/navigating-the-cusma-review-process-a-guide-for-canadian-stakeholders
- https://www.cbh.com/insights/articles/excise-tax-on-remittance-transfers-irc-section-4475-explained/
- https://www.irs.gov/newsroom/irs-releases-tax-inflation-adjustments-for-tax-year-2026-including-amendments-from-the-one-big-beautiful-bill
- https://www.canada.ca/en/revenue-agency/services/tax/businesses/topics/corporations/type-corporation.html
Sincerely,
The State Bird Corp Team
State Bird Corp
P: (602) 641-5996 · E: Info@statebirdcorp.com · W: statebirdcorp.com
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State Bird Corp is a management and financial consulting firm. State Bird Corp is not an accounting, legal or investment advisory firm. Cross-border planning is highly fact-specific. The strategies and topics described are general in nature, and readers should consult qualified specialists before taking any action. Any recommendation, inferences, or other guidance contained herein is meant for educational or general purposes and should not be relayed upon as specific advice for any person or business. Consult your legal, tax, and investment advisor for specific recommendation to your situation.