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Snowbirds US Expats Radio Podcast
Gerry Scott
70 episodes
2 days ago
Whether you're a Canadian snowbird spending winters in the USA, or an American looking to move to Canada, the Snowbirds Expats Radio Podcast is loaded with useful information to guide you. Gerry Scott is the host of this podcast, Monday to Friday, Gerry works with Canadian and US clients as a cross border advisor with one of Canada’s largest and most respected wealth management firms.. The Snowbirds Expats Radio Podcast is brought to you by the Snowbirds US Day Tracker and the Canada Physical Presence Tracker apps. The Snowbirds US Day Tracker app helps you track the number of days you’re spending in the USA, which is essential to avoid being classified by the IRS as a US resident for tax purposes. The Canada Physical Presence Tracker is the easiest and most reliable way to track your physical permanent days for the purpose of renewing your permanent residence card (maple card). Simply enter the days into the calculator and track the progress as you get closer and closer to becoming a full time resident of Canada. Both apps offer a wide variety of services that include, USD exchange, tax and legal services, Real Estate, Medical Tourism, and more. Download them today on your iPhone or Android.
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All content for Snowbirds US Expats Radio Podcast is the property of Gerry Scott and is served directly from their servers with no modification, redirects, or rehosting. The podcast is not affiliated with or endorsed by Podjoint in any way.
Whether you're a Canadian snowbird spending winters in the USA, or an American looking to move to Canada, the Snowbirds Expats Radio Podcast is loaded with useful information to guide you. Gerry Scott is the host of this podcast, Monday to Friday, Gerry works with Canadian and US clients as a cross border advisor with one of Canada’s largest and most respected wealth management firms.. The Snowbirds Expats Radio Podcast is brought to you by the Snowbirds US Day Tracker and the Canada Physical Presence Tracker apps. The Snowbirds US Day Tracker app helps you track the number of days you’re spending in the USA, which is essential to avoid being classified by the IRS as a US resident for tax purposes. The Canada Physical Presence Tracker is the easiest and most reliable way to track your physical permanent days for the purpose of renewing your permanent residence card (maple card). Simply enter the days into the calculator and track the progress as you get closer and closer to becoming a full time resident of Canada. Both apps offer a wide variety of services that include, USD exchange, tax and legal services, Real Estate, Medical Tourism, and more. Download them today on your iPhone or Android.
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Places & Travel
Society & Culture
Episodes (20/70)
Snowbirds US Expats Radio Podcast
Episode 73: Principal Residence Rules Explained: What Cross-Border Homeowners Need to Know

Can your U.S. vacation home qualify as your principal residence in Canada?

Buying, selling, or co-owning a home across the U.S.–Canada border can create a web of unexpected tax implications — especially when both countries have their own rules about what qualifies as a principal residence.

In this episode, Gerry Scott sits down with Karlene Mulraine, a cross-border tax specialist and founder of Brij Professional Corporation, to unpack how principal residence exemptions work on both sides of the border and how cross-border couples can plan smartly before making property decisions.

Karlene, who recently earned her Master’s in Taxation from Golden Gate University, shares her insights on key filing requirements, capital gains rules, and the 2026 Canadian inclusion rate change that could impact future property sales.

🔍 Key Topics Covered

  • 🏡 Principal Residence Rules: How Canada and the U.S. define and tax your main home — and why the details differ.

  • 💍 Cross-Border Couples: What happens when a Canadian marries a U.S. citizen and adds them to the property title.

  • 💸 Capital Gains & Exemptions: Understanding the $250K/$500K U.S. exclusion versus Canada’s unlimited principal residence exemption.

  • 📜 FIRPTA Withholding: What Canadians should expect when selling U.S. real estate and how to reclaim excess tax withheld.

  • 🧾 Claiming Foreign Tax Credits: How proper reporting prevents double taxation between the two countries.

  • 🔁 Upcoming Rule Changes: How Canada’s 2026 capital gains inclusion rate increase could affect property sales.

  • 🌴 Market Trends: Why rising insurance rates, unfavorable exchange rates, and shifting lifestyles are leading more Canadians to sell their U.S. vacation homes.


Visit www.brij.tax to learn more about Bridge Professional Corporation and Karlene’s cross-border tax services.

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5 days ago
24 minutes 52 seconds

Snowbirds US Expats Radio Podcast
Episode 72: Dual Filing Demystified: What Americans Moving to Canada Need to Know

What happens when an American moves to Canada?

Dual filing is one of the most complex (and misunderstood) parts of cross-border life. To help unpack it, this episode of Snowbirds Expat Radio welcomes Robin Veenendaal, an independent CPA and member of SME, a professional network that connects and empowers accountants and lawyers across North America.

With nearly two decades of experience supporting cross-border taxpayers, Robin explains what Americans and green card holders need to know when establishing residency in Canada — including the U.S. exit tax, dual-status filing, and how to avoid costly mistakes.

Listeners will also hear:

  • The key filing obligations for U.S. citizens and green card holders when moving to Canada

  • Why you shouldn’t cash in your IRA or 401(k) before relocating

  • The simple one-time election that keeps your Roth IRA tax-free in Canada

  • How inherited IRAs are taxed differently for Canadian beneficiaries

  • Common mistakes made by returning Canadians and new arrivals — and how to fix them

  • Why it’s critical to coordinate between cross-border accountants, advisors, and immigration lawyers

  • What to do if you realize you’ve missed income reporting or asset disclosures

Robin and Gerry also discuss the rise of the “backdoor Roth” strategy, the pitfalls of using outdated tax advice, and why having a plan before you land can make all the difference.

Resources

📞 Learn more about Robin Veenendaal and SME: www.smesync.com


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2 weeks ago
35 minutes 12 seconds

Snowbirds US Expats Radio Podcast
Episode 71: TFSA or Trouble? What Americans in Canada Need to Know

Should an American living in Canada hold a TFSA—or avoid it? Ask 10 accountants and you might get 15 different answers. That’s why this episode of Snowbirds Expat Radio brings in cross-border tax expert Christa Walkden from 49th Parallel Tax.

With nearly 30 years of experience in U.S. and Canadian taxation, Christa breaks down the complexities around Tax-Free Savings Accounts (TFSAs) for U.S. citizens in Canada. She explains the spectrum of filing positions, from the most conservative (treating the TFSA as a foreign trust with Form 3520 filings) to more practical approaches that rely on disclosure and income reporting.

Listeners will also hear:

  • Why the IRS hasn’t clarified the TFSA’s status—and what that means for you.

  • How Canadian mutual funds inside a TFSA create extra problems under U.S. PFIC rules.

  • The pitfalls of transferring TFSAs into U.S.-owned firms (like capital gains surprises).

  • Why collaboration between advisors, accountants, and immigration lawyers is critical.

  • When it actually makes sense for Americans to keep a TFSA, depending on their other income and foreign tax credits.

Christa and Gerry also touch on the hope that a future treaty update could treat TFSAs the same way Canada treats Roth IRAs—finally bringing clarity for cross-border families.

Resources

📞 Learn more about Crista Walkden & 49th Parallel Tax: https://49ptax.ca/

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1 month ago
24 minutes 51 seconds

Snowbirds US Expats Radio Podcast
Episode 70: Take Your Money and… Come Home? Leaving Canada, Living Abroad, and Coming Back Again

What does it mean to be a snowbird versus an expat? And in today’s uncertain cross-border environment, is Canada becoming the safer destination to return to?

In this episode, Gerry Scott sits down with Alexander Doulis, author of the 1990s bestseller Take Your Money and Run, to revisit his bold ideas about leaving Canada, living abroad, and protecting wealth offshore. Together they explore how those strategies stack up in today’s climate of economic uncertainty, political change, and shifting real estate markets.

Alex explains why he originally left Canada for Ireland and spent 15 years sailing around the world, why many snowbirds are now selling their U.S. properties, and why annuities and offshore trusts continue to play a role in retirement and asset protection. The conversation also touches on private healthcare, cross-border tax strategies such as Roth IRAs, and the enduring popularity of his books My Blue Haven, The Bonds Revenge, Decommissioned, and Tackling the Taxman.

It’s a provocative, entertaining, and sometimes controversial discussion about wealth, residency, and the timeless search for certainty.

Key Takeaways

  • The difference between snowbirds and expats—and why that distinction matters for taxes.

  • Why uncertainty is the greatest risk for investors and retirees on both sides of the border.

  • Real estate pressures leading Canadians to sell U.S. properties and repatriate wealth.

  • The case for annuities and offshore trusts as income and asset-protection tools.

  • How private healthcare could ease strain on Canada’s system.

  • Cross-border opportunities with U.S. Roth IRAs.

  • Why, despite global options, Canada still offers some of the best places to live.

Resources Mentioned

  • Take Your Money and Run by Alexander Christ Doulis

  • My Blue Haven

  • The Bonds Revenge

  • Decommissioned

  • Tackling the Taxman

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1 month ago
41 minutes 4 seconds

Snowbirds US Expats Radio Podcast
Episode 69: Pathways to U.S. Citizenship: What Canadians Need to Know

What does it really take for a Canadian to live full-time in the United States? 

Can citizenship be passed down through a parent or even a grandparent? And what happens to your taxes if you suddenly discover you’ve been a U.S. citizen all along?

In this episode, Gerry Scott welcomes back Robert Clegg, cross-border immigration and tax lawyer, to unravel the rules around U.S. citizenship and residency. Robert explains how derivative citizenship works, what documentation is required, and how the year of birth determines which statutes apply. 

He also walks through employer-sponsored visa options, the reality of holding dual citizenship, and why immigration planning must always be paired with tax planning.

Listeners will hear how the IRS Streamlined Amnesty Program helps new U.S. citizens catch up on filings, how Canada’s departure tax can affect movers, and why younger Canadians often view the move south differently than retirees. 

Whether you’re exploring work opportunities, family ties, or lifestyle choices, this conversation offers a clear-eyed look at what it means to pursue U.S. citizenship as a Canadian.

Website: https://clegglawgroup.com/about-us


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2 months ago
16 minutes 43 seconds

Snowbirds US Expats Radio Podcast
Replay: Episode 62 How WEP Impacts Canadians Collecting CPP & U.S. Social Security

We’re revisiting one of our most popular and practical episodes on Snowbirds Expat Radio—and if you’re a Canadian with ties to both CPP and U.S. Social Security, this one’s for you.

Host Gerry Scott sits down with Sharon Conrod, CPA of Hanson Cross-Border Tax Professional Corporation, to break down the Windfall Elimination Provision (WEP)—what it is, why it exists, and how recent changes may affect Canadians planning for (or already in) retirement.

You’ll also hear about the Government Pension Offset (GPO), the differences between the U.S. and Canadian retirement systems, and what these evolving rules mean for your financial planning across borders.

✅ Key Insights from this Episode:

  • WEP adjusts U.S. Social Security benefits for those receiving non-covered pensions, like CPP.

  • Recent changes could reduce WEP’s impact for many Canadian retirees.

  • GPO operates separately from WEP and specifically affects spousal benefits.

  • Understanding the WEP formula is critical to estimating your benefits.

  • Policy and political shifts may shape the future of WEP.

  • CPP and U.S. Social Security are structured differently, making direct comparisons tricky.

  • Canadians can now apply for CPP without triggering automatic reductions in U.S. benefits.

If you split your working life between Canada and the U.S., this replay is packed with timely, need-to-know information to help you plan smarter for retirement.


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2 months ago
32 minutes 2 seconds

Snowbirds US Expats Radio Podcast
Episode 68: Should You Renounce Your U.S. Citizenship? A Cross-Border Deep Dive

Thinking of giving up your U.S. citizenship? You're not alone—and it's not as simple as it sounds. In this in-depth and timely conversation, Robert Clegg, Cross-Border Tax & Immigration Specialist from Clegg Law Group returns to the Snowbirds Expat Radio podcast to break down the emotional, financial, and legal factors behind renunciation, especially for Canadians who’ve lived in the U.S. or Americans now living abroad.

We discuss:

  • ✅ The advantages and real risks of renouncing U.S. citizenship

  • 💰 How exit taxes, U.S. pensions, and Canadian residency complicate things

  • 🇺🇸 Why some are leaving the U.S. for good—and what’s driving the trend

  • 📄 The truth about losing your Social Security (spoiler: you don’t!)

  • 🧾 Why DIY renouncing rarely ends well

  • ✈️ “Renunciation holidays” and where to fast-track the process abroad

  • 💡 Why timing and tax planning can make or break your renunciation journey

Whether you're a dual citizen thinking of simplifying your tax life or a financial advisor guiding clients through international transitions, this episode is full of key insights.

Contact Robert: https://clegglawgroup.com/home


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2 months ago
28 minutes 47 seconds

Snowbirds US Expats Radio Podcast
REPLAY Episode 51: Expat Taxes, Tax Treaties & the Truth About Renouncing U.S. Citizenship

Can living abroad come with unexpected tax consequences? Absolutely—and we’re bringing back one of our most informative conversations to prove it.

In this replay episode of Snowbirds Expat Radio, host Gerry Scott sits down with Mike Wallace from Greenback Tax to unpack the complexities of U.S. expat taxes. Whether you're a seasoned snowbird, a new digital nomad, or simply living abroad part-time, this episode is a must-listen.

Mike dives deep into tax treaties, IRS compliance, and the growing number of Americans exploring renunciation due to complicated filing obligations. From real-world scenarios to expert guidance, this conversation will help you avoid costly mistakes and gain peace of mind.

💡 Key Takeaways (Still As Relevant As Ever):

  • Greenback Tax Expertise: Greenback Tax helps U.S. citizens worldwide stay IRS-compliant and reduce tax stress abroad.

  • Yes, You Still Have to File: Even if you live overseas, U.S. citizens must file taxes with the IRS—many don’t realize it until it’s too late.

  • Tax Treaties Can Help (If You Know How to Use Them): They can reduce double taxation, but only if applied correctly.

  • Considering Renunciation? Hear why more expats are exploring this option—and the financial consequences it can bring.

  • Remote Work = More Freedom + More Risk: The digital nomad lifestyle is booming, but so are cross-border tax complexities.

  • IRS Is Watching: The IRS has increased efforts to track expats—staying compliant is more important than ever.

  • Canadian Expats, Take Note: Canadians living in the U.S. also face cross-border tax hurdles that shouldn’t be ignored.

  • Greenback’s Role: From tax planning to form filing, Greenback helps clients around the world confidently navigate expat life.

Whether you missed this episode the first time or need a refresher before your next tax season abroad, this replay delivers the clarity and expertise every expat needs.

Resources: 

Michael Wallace on LinkedIn

Greenback Tax Services Website 


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3 months ago
23 minutes

Snowbirds US Expats Radio Podcast
Episode 67: U.S. Registration Requirements for Canadian Snowbirds?

Are Canadian Snowbirds at risk of breaking U.S. law? With new enforcement of a decades-old rule, Canadians staying more than 30 days in the U.S. are now being told to “register”—but what does that really mean?

In this episode of the Snowbirds Expat Radio Podcast, Gerry Scott welcomes immigration lawyer Julia Herzog, of Herzog Legal, who breaks down the recent U.S. executive order and Canada’s updated travel advisory. They explore what this means for seasonal travelers, how to check your I-94 status, whether a Nexus card helps, and what to do if border agents ask to search your phone or laptop.

You’ll learn:

  • What the U.S. registration rule actually says—and why it’s being enforced now

  • How to verify your I-94 status online and what to do if you can’t find it

  • Whether you should apply for a Nexus card, fill out form G-325A, or request a passport stamp

  • What rights border officers have when it comes to your electronic devices

  • What this means for Canadians working remotely or running businesses from the U.S.

🎧 Whether you’re headed to Florida, Arizona, or Hawaii this winter—or you're a cross-border commuter—this is a must-listen episode packed with practical advice from one of Canada’s most trusted cross-border experts.

Guest: Julia Herzog, U.S. and Canadian Immigration Lawyer🎓 Licensed in both NY and British Columbia🌐 herzoglaw.ca

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3 months ago
30 minutes 19 seconds

Snowbirds US Expats Radio Podcast
Episode 66: Cross-Border Car Accidents: What Canadians Need to Know

What happens if you're a Canadian and get into a car accident in the U.S.? This episode is a must-listen for snowbirds, part-time residents, and anyone who drives across the border. Gerry Scott is joined again by personal injury lawyer Andrew Iacobelli, whose cross-border legal expertise helps Canadians navigate the often-confusing world of U.S. auto accidents, insurance claims, and litigation.

From the importance of underinsured motorist coverage to how fast U.S. litigation can move compared to Canada, Andrew breaks down what to do immediately after a crash, what evidence to collect, and why you should never sign a release form without legal advice. He also explains why Americans injured in Canada may have the advantage—and what every Canadian traveler should keep in their glovebox (spoiler: it’s his book!).

Whether you're road-tripping through Florida, spending your winters in Arizona, or just curious about what your insurance actually covers—you’ll want to take notes.

🧠 Key Takeaways:

  • The #1 most important step to take after a U.S. car accident (hint: it’s not calling your insurer).

  • Why travel insurance is critical, especially for snowbirds.

  • How U.S. adjusters evaluate claims—and why Canadian medical records can be a disadvantage.

  • What to know about settlement offers, release forms, and preserving your right to sue.

  • The difference between no-fault benefits and underinsured motorist claims—and how to choose the right one for your case.

  • When to involve lawyers on both sides of the border (and when you might not need to).

  • Why American citizens injured in Canada may actually have stronger negotiating leverage.

  • What Canadians should never do before consulting with a lawyer.

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4 months ago
39 minutes 52 seconds

Snowbirds US Expats Radio Podcast
Episode 65: Costly Mistakes with Cross-Border Taxes To Avoid

If you’re a U.S. citizen living in Canada—or a Canadian with U.S. ties—are you clear on your tax obligations? The answer could be more complicated than you think.

Gerry Scott sits down with cross-border tax attorney Alexey Manasuev from U.S. Tax IQ, to unpack what you really need to know about U.S. and Canadian tax obligations. From foreign retirement accounts to FBAR requirements and residency status, this conversation is packed with insights that could save you thousands—and a major compliance headache.

Key Takeaways:

  • U.S. citizens must file U.S. tax returns—even when living abroad

  • Canadian residents with U.S. ties face unique filing considerations

  • Retirement accounts are not treated equally in both countries

  • FBAR filing is mandatory if your foreign accounts exceed $10,000

  • Non-compliance comes with steep financial penalties

  • The U.S.-Canada tax treaty doesn’t override filing responsibilities

  • Residency status plays a central role in determining obligations

  • Business owners can use strategic planning to manage cross-border tariffs

  • Decision trees can help clarify complex filing questions

  • A qualified tax advisor can make all the difference

Whether you're spending a few months in the U.S., managing dual citizenship, or running a cross-border business, this episode offers clarity in a complicated space.

🎧 Tune in now at snowbirdsusdaytracker.com or wherever you get your podcasts.

#Snowbirds #CrossBorderTax #USCanadaTax #ExpatPlanning #RetirementTaxes #GerryScott #AlexeyManasuev #SnowbirdsExpatRadio #FBAR #TaxResidency #RaymondJamesCanada #SnowbirdsUSDayTracker


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5 months ago
26 minutes 16 seconds

Snowbirds US Expats Radio Podcast
Episode 64: Selling U.S. Property as a Canadian: What You Need to Know

What really happens when a Canadian sells property in the U.S.—and how do you avoid unexpected tax surprises?

In this episode of Snowbirds Expat Radio, host Gerry Scott welcomes cross-border tax professional Steven Flynn to discuss the growing trend of Canadians selling real estate in the U.S., particularly in sunny destinations like Florida and Arizona.

They break down the key tax implications, from federal withholding rules to state-specific obligations, and explain why Canadians need to file U.S. tax returns to reclaim overpaid taxes. The conversation also highlights the importance of foreign tax credits, how estate sales are handled, and why pre-sale planning can make all the difference.

Whether you're actively selling or just starting to explore the process, this episode offers practical insight to help you prepare and protect your financial interests.

Key Takeaways:

✅ Growing Trend: More Canadians are choosing to sell their U.S. properties due to lifestyle and financial changes.

✅ Federal Withholding Applies: The IRS withholds a portion of the sale price from non-resident sellers.

✅ State Tax Rules Vary: Tax responsibilities can differ significantly from state to state.

✅ Tax Filing Required: Canadians must file a U.S. tax return to report the sale and request refunds.

✅ Foreign Tax Credits Help: These credits can reduce or eliminate double taxation between Canada and the U.S.

✅ Estate Sales Follow Similar Rules: Estates must also comply with U.S. tax filing and withholding requirements.

✅ Plan Before You Sell: Early tax planning can help avoid surprises and maximize your net proceeds.

✅ IRS ID Requirements: Sellers may need to obtain a U.S. tax identification number.

✅ Refunds Can Be Lost: Missing tax filing deadlines may result in forfeiting refunds.

✅ Professional Help Makes a Difference: Having the right guidance can simplify a complex process.

🎧 Tune in now on your favorite podcast platform for an informative look at cross-border property sales.

🔗 Subscribe to Snowbirds Expat Radio for more conversations on real estate, taxes, and expat living.

📢 Questions or comments? We’d love to hear from you!#Snowbirds #CanadianInUSA #USTaxForCanadians #CrossBorderLiving #RealEstateAbroad

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5 months ago
35 minutes 47 seconds

Snowbirds US Expats Radio Podcast
Tariffs, Trade, and the Snowbird Economy

How do rising tariffs between the U.S. and Canada really impact your wallet—and your winter lifestyle?

In this episode, host Gerry Scott welcomes international trade and tax professional, Dan Kiselbach of Miller Thomson to break down what snowbirds and Canadian retirees need to know about the shifting trade landscape. From the price of beer to cross-border legal protections, this conversation unpacks the real-life implications of tariffs, currency instability, and political shifts.

Whether you winter in Florida or invest across borders, this episode offers valuable insight on protecting your financial future.

Key Takeaways:

  • Tariffs are driving up consumer prices—especially in everyday goods.

  • Canadian retirees could feel the pinch on both sides of the border.

  • Canada’s retaliatory moves are precise and strategic.

  • Legal protections for Canadians exist under trade agreements.

  • Currency fluctuations may weaken spending power in the U.S.

  • Investment opportunities may shift with trade uncertainty.

  • Political predictions lean toward continued liberal leadership.

  • Historical tariffs continue to shape today’s economy.

  • Delaware remains a popular business base thanks to its legal structure.

🎧 Tune in now to stay informed—and stay prepared.

#SnowbirdExpatRadio #TariffTalk #CrossBorderLiving #SmartSnowbirding

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6 months ago
29 minutes 25 seconds

Snowbirds US Expats Radio Podcast
Vancouver Gerry and Toronto Mike Discuss the 2025 Canadian Election

Gerry Scott and Toronto Mike discuss the 2025 Canadian federal election, how the country came to be so divided, and what should be done to unite the true north strong and free.

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6 months ago
29 minutes 11 seconds

Snowbirds US Expats Radio Podcast
Episode 62: What Canadians Need to Know About WEP and U.S. Social Security

How does the Windfall Elimination Provision affect Canadians collecting both CPP and U.S. Social Security—and what’s changing?

In this episode of Snowbirds Expat Radio, host Gerry Scott is joined by guest Sharon Conrod, CPA of Hanson Cross-border Tax Professional Corporation for an in-depth conversation about the Windfall Elimination Provision (WEP) and its implications for cross-border retirees. Together, they explore the history of WEP, recent updates, and how these changes may benefit Canadians who have worked in both countries.

The discussion also touches on the Government Pension Offset (GPO), the differences between U.S. and Canadian retirement systems, and the importance of understanding how these policies intersect.

If you're planning your retirement across borders—or already collecting benefits—this episode provides timely insight into how these evolving rules may impact your financial planning.

Key Takeaways:

  • WEP was designed to adjust U.S. Social Security benefits for individuals receiving non-covered pensions, like Canada’s CPP.

  • Recent changes may help reduce the impact of WEP for many Canadian retirees.

  • The Government Pension Offset (GPO) affects spousal benefits and operates separately from WEP.

  • Understanding the WEP calculation formula is essential to estimate your actual benefits.

  • Political developments may influence the future of WEP and Social Security rules.

  • Comparing CPP and U.S. Social Security isn’t always straightforward due to structural and tax differences.

  • Canadian residents can now apply for CPP without worrying about automatic reductions to U.S. benefits.

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6 months ago
32 minutes 2 seconds

Snowbirds US Expats Radio Podcast
Cross-Border Inheritance: What Canadian Beneficiaries Need to Know

In this episode, host Gerry Scott is joined once again by Aaron Dawes, a cross-border tax specialist with Smythe LLP, for Part 2 of their discussion on estate planning across the U.S.-Canada border.

This conversation dives into the complexities that arise when Canadian children inherit assets from American parents—a growing issue in cross-border wealth management. Aaron breaks down the tax implications, planning considerations, and often-overlooked pitfalls families face when navigating real estate, IRAs, cash inheritances, and U.S. estate tax rules. He also emphasizes the critical role of cross-border tax advisors and estate lawyers in avoiding delays, penalties, or double taxation.

👉 If you haven’t already, check out Part 1 for the U.S. perspective on cross-border inheritance and key foundational insights.

What You’ll Learn in Part 2:

  • How U.S. estate tax applies to high-net-worth individuals

  • The benefits of inherited IRAs vs. lump-sum distributions

  • When and how cross-border tax treaties come into play

  • Why cash is easy but real estate can be tricky to inherit across borders

  • How late filings can result in steep penalties

  • The importance of having cross-border professionals on your estate planning team

  • How family dynamics can complicate even the best-laid plans

This is an essential listen for anyone managing assets across borders, navigating family inheritance, or helping clients prepare for a smooth generational transfer.

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6 months ago
20 minutes 40 seconds

Snowbirds US Expats Radio Podcast
Episode 60: U.S. Beneficiaries Inheriting Canadian Assets: What You Need to Know

Ever wondered what really happens when a U.S. citizen inherits assets from their Canadian parents?

Spoiler: it's not as simple as you’d think.

In today’s episode, host Gerry Scott sits down with Aaron Dawes, cross-border tax expert from Smythe LLP, to unpack the increasingly common—but often misunderstood—scenario of U.S. individuals inheriting Canadian assets. With more families living cross-border lifestyles and adult children relocating south, questions around tax, compliance, and estate planning have taken on a whole new level of complexity.

Aaron breaks down what Americans need to know when it comes to Canadian inheritances—covering everything from brokerage accounts and real estate to RRSPs and even mutual funds (hello, PFIC reporting!). He also shares important guidance for Canadian parents who want to ensure their U.S.-based children don’t end up tangled in unnecessary tax trouble.

Plus, they touch on the rise of dual-country living, why California residents often get the short end of the treaty stick, and what both sides of the border can do to minimize the risk of double taxation.

Whether you're the beneficiary, the planner, or somewhere in between, this episode will give you a better understanding of the tax landscape and how to protect your assets—and your sanity.

Key Takeaways:

  • What U.S. beneficiaries need to report when inheriting Canadian assets

  • Why Canadian mutual funds can trigger complicated (and costly) U.S. tax filings

  • How the Canada–U.S. tax treaty works—and when it doesn’t

  • The role of executors and why residency matters

  • Steps Canadian parents can take now to ease the future burden on their U.S. children

About the Guest:

Aaron Dawes, CPA, is a partner at Smythe LLP, a British Columbia-based accounting firm with offices in Vancouver, Langley, and Nanaimo. Specializing in U.S.-Canada cross-border taxation, Aaron works closely with families and business owners navigating complex estate, income, and compliance matters across borders.

Next Episode Teaser:

Stay tuned for part two, where we flip the script: What Canadian beneficiaries need to know when inheriting from U.S. parents—especially when irrevocable trusts come into play.🔗 

Helpful Links:

  • Smythe LLP: https://www.smythecpa.com

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7 months ago
22 minutes 55 seconds

Snowbirds US Expats Radio Podcast
Episode 59: The Cross-Border Estate & Tax Mistakes Canadians Can’t Afford to Make

What happens to your estate and taxes if you’re a Canadian living in the U.S.? 🤔 Many people assume their Canadian will and financial plans will carry over—but cross-border estate and tax laws are far more complicated than they seem.

In this episode, Gerry Scott sits down with Carol Sadler, a cross-border tax professional from Achen Henderson, to break down the biggest financial, legal, and tax mistakes Canadians make when moving to the U.S.—and how to avoid them.

They discuss:

✅ Residency & Tax Rules – Why “where your feet are” matters for Canadian tax status.

✅ Estate Planning Pitfalls – Why keeping only a Canadian will could create major legal delays in the U.S.

✅ Cross-Border Executor Issues – Can your Canadian kids legally settle your U.S. estate?

✅ U.S. Estate Tax Risks – How high-net-worth individuals can reduce tax exposure.

✅ Banking & Financial Hurdles – Why opening U.S. estate accounts is harder than you think.

✅ The #1 Legal Document Every Snowbird Needs in the U.S.

From common estate pitfalls to practical tax solutions, this episode is packed with expert insights to help Canadians navigate cross-border financial life with confidence.

📌 Want to avoid tax surprises? Download the Snowbirds US Day Tracker App to track your days in the U.S. and stay compliant with immigration and tax rules.

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7 months ago
31 minutes 40 seconds

Snowbirds US Expats Radio Podcast
The Net Investment Income Tax & Its Impact on U.S. Expats in Canada

In this episode of Snowbirds Expat Radio, host Gerry Scott sits down with tax expert Robert Clegg to unpack the Net Investment Income Tax (NIIT) and how it affects American expatriates—particularly those living in Canada. They explore how this tax applies to real estate transactions, investment income, and the risk of double taxation, as well as the latest updates on foreign tax credits and tax treaties.

Robert also provides insights into the complex process of renouncing U.S. citizenship, explaining both the legal and tax considerations. With recent court rulings potentially altering foreign tax credit applications, this episode is a must-listen for expats looking to navigate U.S. tax laws effectively.

Key Takeaways:

✅ What is the NIIT? – The Net Investment Income Tax applies to passive income, including real estate sales and investment gains.

✅ Double Taxation Risks – U.S. citizens in Canada may face double taxation, as foreign tax credits do not currently apply to NIIT under IRS rules.

✅ Real Estate & NIIT – The sale of real property is considered passive income, making it subject to NIIT taxation.

✅ Foreign Tax Credits & Court Rulings – While NIIT does not qualify for foreign tax credits, recent legal decisions may change how the tax is applied to expats.

✅ Renouncing U.S. Citizenship – Robert explains why the process is becoming more complex and requires careful tax and immigration planning.

✅ Tax Treaties & Expats – Tax treaties between the U.S. and Canada help reduce double taxation, but gaps still exist, especially for investment income.

✅ Why Was NIIT Introduced? – Originally implemented to fund healthcare subsidies under the Affordable Care Act, NIIT has had unintended tax consequences for expats.

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8 months ago
33 minutes 43 seconds

Snowbirds US Expats Radio Podcast
Episode 57: Navigating Cross-Border Legal Challenges: What Canadians Need to Know

What would you do if you got into an accident while driving in the U.S.? Would your Canadian insurance cover you? Do you know your legal rights? In this episode of Snowbirds Expat Radio, host Gerry Scott sits down with cross-border personal injury lawyer Andrew Iacobelli to break down the complexities of legal issues faced by Canadians traveling to the United States. They explore key differences between the Canadian and American legal systems, how insurance policies work across borders, and the most common mistakes Canadians make when dealing with accidents abroad. Andrew shares expert advice on underinsured motorist coverage, travel health insurance, and how public adjusters handle claims in the U.S.

Key Takeaways:

✅ Canadians need to understand their legal rights when traveling in the U.S.

✅ Damage awards in the U.S. are significantly different from those in Canada.

✅ Renting a car in the U.S. can create unexpected insurance complications.

✅ No-fault insurance in British Columbia has specific implications for travelers

.✅ The majority of legal inquiries from Canadians involve car accidents.

✅ Underinsured motorist coverage is often overlooked but crucial.

✅ Misconceptions about legal support can lead to poor decisions post-accident.

✅ Travel health insurance is essential for Canadians visiting the U.S.

✅ Owning a car in the U.S. can limit rights under Canadian insurance policies.

✅ Public adjusters play a key role in property damage claims in the U.S., unlike in Canada.

Why This Matters for Snowbirds & Expats:

If you travel frequently between Canada and the U.S., understanding these legal and insurance nuances can help you avoid costly mistakes and ensure you’re adequately protected. Whether you’re renting a car, dealing with an accident, or navigating an insurance claim, this episode provides crucial insights to keep you informed and prepared.

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8 months ago
32 minutes 15 seconds

Snowbirds US Expats Radio Podcast
Whether you're a Canadian snowbird spending winters in the USA, or an American looking to move to Canada, the Snowbirds Expats Radio Podcast is loaded with useful information to guide you. Gerry Scott is the host of this podcast, Monday to Friday, Gerry works with Canadian and US clients as a cross border advisor with one of Canada’s largest and most respected wealth management firms.. The Snowbirds Expats Radio Podcast is brought to you by the Snowbirds US Day Tracker and the Canada Physical Presence Tracker apps. The Snowbirds US Day Tracker app helps you track the number of days you’re spending in the USA, which is essential to avoid being classified by the IRS as a US resident for tax purposes. The Canada Physical Presence Tracker is the easiest and most reliable way to track your physical permanent days for the purpose of renewing your permanent residence card (maple card). Simply enter the days into the calculator and track the progress as you get closer and closer to becoming a full time resident of Canada. Both apps offer a wide variety of services that include, USD exchange, tax and legal services, Real Estate, Medical Tourism, and more. Download them today on your iPhone or Android.