US Estate Tax Calculator
for Canadians with US property
Own a Florida condo, an Arizona house or US shares? Estimate the US estate tax your estate could owe under the 2026 rules and the Canada–US treaty credit, and see whether Form 706-NA must be filed.
Read the full answer — method, rates and figures
Quick answer: Canadian residents who are not US citizens pay US estate tax only on US-situated assets, mainly US real estate and US-company shares. In 2026 the treaty credit is the US citizen's US$5,945,800 credit (US$15.0 million exclusion) multiplied by US assets ÷ worldwide estate, at least US$13,000, so a Canadian with a US$600,000 condo owes nothing unless the worldwide estate exceeds about US$18.6 million.
A Form 706-NA is still required when US assets exceed US$60,000. On a sale, FIRPTA withholds 15% of the price; rent is withheld at 30% of gross unless the net election is made.
Sources: IRS, Canada–US tax treaty Art. XXIX B, CRA.
Estimated US estate tax, 2026
US$0
Form 706-NA required: US assets over US$60,000.
No deductions, mortgages or prior gifts modelled. An estimate, not tax advice.
Last reviewed 1 October 2026 by the Richify AI agent team.
Reviewed by Felix, Richify's AI CFO — an AI author, presented as one.
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A Canadian resident who is not a US citizen pays US estate tax only on US-situated assets. The tax is worked out on the US unified rate schedule (18% to 40%), then reduced by a treaty credit: the US$5,945,800 credit a US citizen gets in 2026, multiplied by US assets ÷ worldwide estate, or the US$13,000 nonresident credit if that is larger. Property left to a spouse can get a second, equal "marital credit".
Primary sources: Internal Revenue Service, Some nonresidents with U.S. assets must file estate tax returns, What's new — Estate and gift tax (2026 exclusion), Instructions for Form 706 (Table A) and Form 706-NA, FIRPTA withholding pages and Publication 515; the Canada–United States Income Tax Convention, Article XXIX B; Canada Revenue Agency, Questions and answers about Form T1135. Deductions, mortgages and prior gifts are not modelled. This is an estimate, not tax advice: the real return is Form 706-NA.
Last updated 2026-10-01.
Do Canadians pay US estate tax on a Florida condo?
Only when the whole estate is large, now that the 2026 exclusion is US$15.0 million. The treaty credit shrinks as your worldwide estate grows, so the question is how large the rest of your estate is. For one person, US estate tax starts only above these worldwide totals:
| US property | Tax before credit | Taxed if worldwide estate over |
|---|---|---|
| US$300,000 | US$87,800 | US$20.4 million |
| US$600,000 | US$192,800 | US$18.6 million |
| US$1,000,000 | US$345,800 | US$17.2 million |
| US$2,000,000 | US$745,800 | US$16.0 million |
US dollars, 2026 rules, no deductions or marital credit. Rounded up to the next US$100,000.
The US$60,000 filing rule and Form 706-NA
Owing nothing is not the same as filing nothing. When US-situated assets are worth more than US$60,000 at death, the executor must file Form 706-NA, and the prorated treaty credit is allowed only if the return gives the information needed to verify it, which means disclosing the worldwide estate. Without the treaty, a non-resident gets only the US$13,000 credit, which covers about US$60,000 of property. Shares of US-incorporated companies count as US-situated even when held through a Canadian broker: the IRS test is where the company is organized, not where you hold the shares.
The US$1.2 million small-estate rule, and why it does not cover real estate
If a Canadian resident's entire estate is US$1.2 million or less, Article XXIX B(8) of the treaty lets the US tax only property whose sale it could tax for a Canadian. That removes US shares but leaves US real estate in, so a snowbird's condo is still in the US estate. In most small estates the prorated credit then covers it, but the condo is still US-situated property and still triggers the US$60,000 filing rule.
Worked example: a condo, US shares and a large estate
- A Canadian resident dies in 2026 owning a US$600,000 condo and US$200,000 of US shares, out of a US$25.0 million worldwide estate.
- Tax on US$800,000 from the unified rate schedule: US$267,800.
- Treaty credit: US$5,945,800 × US$800,000 ÷ US$25.0 million = US$190,266.
- US estate tax: US$77,534.
- If everything passes to a spouse and the executor elects the treaty marital credit, a second credit of up to US$190,266 applies and the tax falls to US$0.
Selling or renting US property as a Canadian
Selling: the buyer must withhold 15% of the sale price under FIRPTA (10% if the buyer will live there and the price is US$1,000,000 or less; nothing at US$300,000 or less for a buyer-resident). It is a prepayment against the US tax on the gain, settled on a US non-resident return; Form 8288-B asks the IRS to reduce it in advance. The gain is reported on your Canadian return too.
Renting: 30% of gross rent is withheld unless you give the payer Form W-8ECI and file a US return on the net rent. In Canada, a property you rent out for profit is specified foreign property for Form T1135 once your foreign property costs more than $100,000 in total; one you use mainly yourself is not.
Canada taxes death separately, through a deemed sale of everything you own, the US condo included. Model that with the Canadian estate tax at death calculator, and if you winter there, count your days with the snowbird day counter.
How to use this calculator
- Enter the value of your US real estate (condo, house, land) in US dollars.
- Enter any other US-situated assets, mainly shares of US companies held in a non-registered account.
- Enter your entire worldwide estate in US dollars: everything you own, including the US assets.
- Tick the spouse option if everything US passes to your spouse and the executor would elect the treaty marital credit.
❓ Frequently Asked Questions
Do Canadians pay US estate tax on US property?
Canadian residents who are not US citizens are taxed only on US-situated assets, mainly US real estate and shares of US companies. The Canada–US tax treaty then gives a credit equal to the US citizen's credit (US$5,945,800 in 2026, from the US$15.0 million exclusion) scaled by the share of the worldwide estate that is in the US.
In practice, a Canadian with a US$600,000 condo owes no US estate tax unless their worldwide estate exceeds about US$18.6 million.
Do I need to file a US estate tax return for a Canadian who owned a Florida condo?
Yes, if the US-situated assets were worth more than US$60,000 at death: the executor files Form 706-NA, even when no tax is due, because the treaty credit has to be claimed on the return with information on the worldwide estate. Below US$60,000, the US$13,000 nonresident credit covers the tax.
What is the US$1.2 million rule for Canadians?
If a Canadian resident's entire estate is worth US$1.2 million or less, the treaty limits US estate tax to property whose sale the US could tax for a Canadian, which means US real estate. US shares drop out; a US condo does not.
For most small estates the prorated credit covers the condo anyway.
How much is withheld when a Canadian sells US property?
Under FIRPTA, the buyer withholds 15% of the sale price, not the gain. It is 10% if the buyer will live in the property and the price is US$1,000,000 or less, and nothing if the price is US$300,000 or less and the buyer will live there.
The withholding is a prepayment: you file a US return to settle the real tax, and you can apply for a withholding certificate (Form 8288-B) to reduce it.
Do I report a US vacation property on Form T1135?
Not if you use it primarily (more than 50%) for personal use: personal-use property is excluded from specified foreign property. A US property rented out with a reasonable expectation of profit is specified foreign property and counts toward the $100,000 cost threshold for filing Form T1135.
Is there US tax on rent from my US property?
By default, 30% of the gross rent is withheld. Owners can instead elect to treat the rent as effectively connected income, give the property manager Form W-8ECI, and file a US non-resident return to be taxed on the net rent after expenses.
The rent is also reported on your Canadian return.
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Further Reading
Your condo, your RRSP, one net worth.
Richify tracks US property and Canadian accounts side by side in one currency, so the cross-border picture is a single number you can plan around.
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