Michael Cirone

Background

About Michael Cirone

Michael is a senior Canadian and U.S. licensed lawyer practicing exclusively in the area of Canada/U.S. cross-border tax, trust and estate planning for Canadians with U.S. connections. A. Canada/U.S. Cross-border Estate Planning:(i) Cross-border Wills, Spousal Bypass Trusts, and Dynasty Trusts for: o U.S. citizens married to Canadians o Canadian parents with U.S. citizen or U.S. resident children o U.S. residents with Canadian assets (ii) Cross-border Alter Ego Trusts and Joint Partner Trusts for U.S. citizens living in Canada who are 65 years and older to achieve provincial probate tax savings and incapacity planning B. Purchase of US Real Estate by Canadians:(i) Set up of Canada/U.S. cross-border trusts and limited partnership structures to protect against U.S. estate tax and personal liability (ii) Restructuring ownership of U.S. real estate to achieve greater Canada/U.S. tax-efficiency C. Lifetime Gifting Strategies for U.S. Citizens and U.S. Green Card Holders Living in Canada:(i) Cross-border tax planning to eliminate U.S. tax on the sale of a Canadian principal residence D. Moving from the U.S. to Canada:(i) Tax planning for U.S. citizens/U.S. green card holders moving from the U.S. to Canada, including: o Renouncing U.S. citizenship o Relinquishing U.S. green cards o Minimizing U.S. exit tax and eliminating U.S. covered expatriate status o Canadian tax residency planning o Restructuring U.S. assets (LLCs, U.S. revocable living trusts, U.S. retirement accounts, U.S. non- registered accounts) to maximize tax-efficiency once in Canada