Personal Tax Planning: Sorry, Eh? How a US-Citizen Spouse Can Complicate Canadian Tax-Saving Strategies

Megan Dalton & Bilaal Bana

Canadian Tax Journal2025https://doi.org/10.32721/ctj.2025.73.2.ptparticle
ABDC A*
Weight
0.50

Abstract

Although Canadian-resident spouses can implement effective income-splitting strategies to limit their income tax exposure, this planning is often more complex when one spouse is a US citizen. Because US citizens are subject to US tax laws, many common Canadian income-splitting strategies must take additional US obligations into account, particularly income and gift taxes. Key strategies that may need to be reconsidered include the payment of family expenses by the higher-income spouse and the use of joint accounts, spousal loans, spousal registered retirement savings account contributions, pension income splitting, tax-free savings accounts, and the use of a Canadian family trust. This article assesses each of these strategies under Canadian tax law, examines how the strategy would be treated under US tax law, and discusses the impacts on a US-citizen spouse and their non-US-citizen spouse. The article also highlights the importance of seeking advice to navigate the complexities of tax planning in this situation and demonstrates that, without proper planning, these Canadian couples could face adverse tax consequences.

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https://doi.org/https://doi.org/10.32721/ctj.2025.73.2.ptp

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@article{megan2025,
  title        = {{Personal Tax Planning: Sorry, Eh? How a US-Citizen Spouse Can Complicate Canadian Tax-Saving Strategies}},
  author       = {Megan Dalton & Bilaal Bana},
  journal      = {Canadian Tax Journal},
  year         = {2025},
  doi          = {https://doi.org/https://doi.org/10.32721/ctj.2025.73.2.ptp},
}

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Evidence weight

0.50

Balanced mode · F 0.40 / M 0.15 / V 0.05 / R 0.40

F · citation impact0.50 × 0.4 = 0.20
M · momentum0.50 × 0.15 = 0.07
V · venue signal0.50 × 0.05 = 0.03
R · text relevance †0.50 × 0.4 = 0.20

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