Snowbirds US Expats Radio Podcast

Gerry Scott

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.

  1. Jul 28

    Episode 92: The Great Return — Gerry’s New Book on Moving Home from the USEpisode 92: The Great Return — Gerry’s New Book on Moving Home from the US

    Guest Host: Laura Garfield | Co-Founder, Idea Decanter  |  Guest: Gerry Scott You spent years building a life in the US - a green card, a career, maybe even citizenship. So what happens to your taxes, your investments, and your retirement accounts the moment you decide to move back home to Canada? The tables are turned this episode: Laura Garfield, co-founder of Idea Decanter, steps in as host to interview Gerry Scott about his brand new book, The Great Return: Canadian's Guide to Moving Home from the US. It's the companion to Gerry's first book, Canadians Heading South for the Winters, and this time it's written for the reverse journey - Canadians coming home after years in the US, and Americans making the move north. Gerry and Laura get into why this move feels deceptively easy (same language, similar culture) when in reality it means untangling two completely different tax systems, the CRA and the IRS. They cover exit tax and the difference between a covered and non-covered expat, why cross-border financial advisors can't legally follow clients across the border, and why DIY moves so often lead to expensive mistakes. Laura also shares her own cross-Canada train trip, and Gerry brings up the Lost Canadians genealogy angle for Americans who may already qualify for Canadian citizenship. What You'll Learn Who The Great Return was written for, and why it applies to Americans moving to Canada too Why the CRA and IRS don't line up, even though crossing the border barely feels like leaving home The difference between a covered and non-covered expat, and why it matters for exit tax Why US states like California and Hawaii don't recognize the Canada-US tax treaty Why your US financial advisor can't legally advise you once you move to Canada What happens tax-wise to Roth contributions, employee stock purchase plans, and pensions after the move How the Lost Canadians genealogy path could mean Americans already qualify for citizenship Resources & Links The Great Return: Canadian's Guide to Moving Home from the US — letsmovetocanada.ca Canadians Heading South for the Winters — snowbirdsheadingsouth.com Snowbirds US DayTracker — snowbirdsusdaytracker.com

    Episode 92: The Great Return — Gerry’s New Book on Moving Home from the USEpisode 92: The Great Return — Gerry’s New Book on Moving Home from the US
  2. Jul 14

    Episode: 91 Cross-Border Death and Taxes: Estate Planning for Canadians with US Assets

    Nobody wants to think about what happens to their Florida condo or Arizona snowbird home after they're gone. But if you're a Canadian with US property and you haven't planned for it, your family could be facing an audit, a probate mess, and tax consequences that were entirely avoidable. That's the reality cross-border tax attorney Alexey Manasuev sees again and again in his practice, and it's exactly what he unpacks in this episode. Alexey returns to the show from Tampa Bay to talk with Gerry about cross-border estate and tax planning for Canadian snowbirds. Alexey is a US tax attorney admitted in New York and DC, and the founder of US Tax IQ, a boutique firm focused exclusively on US international tax planning, compliance, and structuring. Together, Gerry and Alexey dig into what really happens when a Canadian passes away owning US real estate without a plan in place, and how to make sure that doesn't happen to you. What You'll Learn in This Episode Why proactive planning matters: Alexey explains how problems with US property often surface only after death, when probate alerts the IRS to gaps left decades earlier, turning what should have been a non-issue into an audit. US estate tax exposure for Canadian-owned property: how a Florida, Arizona, or other US property can trigger US estate and gift tax obligations for a Canadian owner, even without US citizenship or residency. Domicile vs. residency: why US estate and gift tax exposure is based on the legal concept of domicile, a facts-and-circumstances test built around intent, not the same as ordinary tax residency. The LLC trap: why an LLC structure that a local US advisor recommends for domestic buyers can create serious problems for Canadian owners on both sides of the border. One will or two: when a single will can work for a cross-border estate, and why a US power of attorney for incapacity and medical decisions is often more important than a second will. The 2026 estate tax exemption threshold: how the $15 million federal base exclusion amount taking effect in 2026 factors into planning decisions. Sell now or hold for the next generation: the shifting trend Alexey is seeing, with some families selling US property as they age while others hold on for the lifestyle and pass it down. Why "campfire advice" is dangerous: why casual, well-meaning tips from friends, neighbors, or a local advisor unfamiliar with cross-border rules can create costly problems, and why a paid consultation with a qualified cross-border tax professional pays for itself. Resources and Links US Tax IQ Snowbirds US Day Tracker App Canadians Heading South for the Winters: What You Don't Know Will Hurt You, by Gerry Scott

    Episode: 91 Cross-Border Death and Taxes: Estate Planning for Canadians with US Assets
  3. Jun 30

    Episode 90: You Might Already Be Canadian and Not Know It

    If you have a Canadian ancestor somewhere in your family tree, you might not need to look very far back. A landmark change to Canadian citizenship law means that for millions of people, especially Americans, that ancestry could now open the door to a Canadian passport. And the person who can help you find that door is a genealogist. This week Gerry sits down with Sheila Hobeck, professional genealogist and founder of Kinalytic, based in Oakville, Ontario, to walk through what Bill C-3 actually means, how to document your Canadian lineage, and why DNA is rewriting family histories that paper records tried to keep buried. What You'll Learn in This Episode What Bill C-3 actually changes: effective December 2025, Canada eliminated the generational limit on citizenship by descent, meaning a Canadian ancestor anywhere in your history, if you can document it, may be enough to claim Canadian citizenshipWho counts as a lost Canadian and why historical acts stripped citizenship from individuals through marriage, birth abroad, and other circumstances that Bill C-3 now addressesHow to start the process through IRCC, when to bring in a Regulated Canadian Immigration Consultant, and when the situation calls for an immigration lawyerWhere genealogists search, from Ancestry and FamilySearch to physical archives and historical societies, and why not everything has been digitizedThe role of DNA in confirming lineage, identifying unknown relatives, and uncovering what Sheila calls NPEs, non-paternity events, where documents and biology don't matchHow AI is helping translate old records written in Quebec French, Latin, and paleographic script, and point researchers toward the right archivesWhy this matters beyond immigration, and what your ancestors' risks and journeys reveal once you start diggingResources and Links Sheila Hobeck, Kinalytic: kinalytic.comIRCC, Immigration, Refugees and Citizenship Canada: canada.ca/en/immigration-refugees-citizenshipFamilySearch (free): familysearch.orgAncestry: ancestry.caGEDmatch: gedmatch.comFamilyTreeDNA: familytreedna.comTrack your days across the border with DayTracker: snowbirdsusdaytracker.comCanadians Heading South - Buy the Book: snowbirdsheadingsouth.com

    Episode 90: You Might Already Be Canadian and Not Know It
  4. Jun 16

    Episode 89: The U.S. Exit Tax and the 8-Out-of-15-Year Rule

    What Canadian Green Card Holders Need to Know Before They Surrender Status Guest: Robert Clegg, CanadAmerican Tax Services  |  Host: Gerry Scott Episode Overview A lot of Canadians who built a life in the United States assume that walking away from a green card is as simple as handing it back at the border. It is not. In this episode, Gerry sits down with cross-border tax specialist Robert Clegg of CanadAmerican Tax Services to unpack the U.S. Exit Tax, the rule that can turn a routine move back to Canada into a six-figure tax bill. Robert walks through how the IRS decides who counts as a covered expat, why the 8-out-of-15-year rule catches long-term green card holders off guard, and what really happens at the border when an officer decides your green card has been abandoned. Real client scenarios, including a near miss at the seven-year mark, illustrate just how much timing matters. Whether you are holding onto a green card out of habit, weighing citizenship, or planning your eventual return to Canada, this conversation lays out exactly what to check before you make a move. What You'll Learn What the U.S. Exit Tax actually is, and how it mirrors Canada's departure tax with a mark-to-market calculation on the day you renounce or abandon status The $2 million net worth threshold that determines whether you're a covered expat, and the roughly $800,000 exclusion available against any deemed gain Why deferred compensation, including 401(k)s and RRSPs, faces a 30 percent withholding if you're a covered expat, and why CPP, OAS, and Social Security are treated differently The 8-out-of-15-year rule for green card holders, including how even one day of residency in a given year counts toward the eight Why a green card does not simply expire after ten years for tax purposes, and the official abandonment process required to stop U.S. filing obligations How border officers assess whether you've abandoned your green card by living in Canada, and what filing a Canadian tax return as a resident signals What a reentry permit is and how it protects green card holders who plan to spend up to two years outside the U.S. without losing status Why there's no do-over once a green card is surrendered, and the limited exceptions for U.S. citizen spouses or children The case for taking U.S. citizenship before moving back to Canada if you ever want unrestricted reentry, including the Medicare timing consideration for retirees under 65 Practical consequences of renouncing, from B-2 visitor day limits to firearm import restrictions to how a Canadian DUI or criminal record can bar reentry for former citizens Resources & Links Guest: Robert Clegg, CanadAmerican Tax Services - cross-border personal, corporate, and partnership tax planning https://www.canadamericantax.com/meet-us.php IRS Form 8854, Initial and Annual Expatriation Statement: https://www.irs.gov/forms-pubs/about-form-8854 USCIS Form I-131, Application for Travel Document (includes the reentry permit for green card holders): https://www.uscis.gov/i-131 USCIS naturalization eligibility tool: https://www.uscis.gov/citizenship snowbirdsheadingsouth.com

    Episode 89: The U.S. Exit Tax and the 8-Out-of-15-Year Rule
  5. Jun 2

    Episode 88: The Hidden Tax Shock: Selling Your US Property as a Canadian

    If you bought a place in Arizona or Maui twenty years ago and never thought about what happens to it when you sell, or when you die, could it already be too late to avoid a tax shock you never saw coming? This week Gerry sits down with Robert M. Clegg, JD, LL.M, of CanadAmerican Tax Services, a dual Canadian and US cross-border tax specialist based on Vancouver Island, to walk through what really happens when a Canadian sells US real estate. From FIRPTA withholding and ITIN requirements to the currency trap and the long road of selling a property after an owner has died, this is the conversation to have before you let a realtor put the sign on the lawn. What You'll Learn in This Episode - Why your first call should be to a cross-border accountant, not the realtor, and how that single move takes the hidden tax shock off the table before the sign ever goes up - FIRPTA explained: how 10 to 15 percent of your gross sale price gets withheld up front, why California and Hawaii add their own layer on top, and why Arizona, Texas, and Nevada do not - Why each non-resident Canadian spouse must file a separate 1040NR with their own ITIN, and how escrow companies routinely get this wrong by issuing one withholding slip under a single number - The currency trap: how a weak Canadian dollar can turn a 700,000 US gain into a far bigger Canadian one, and why you need the exchange rate at purchase, at sale, and at every renovation - How the foreign tax credit stops you from being taxed twice, why only half your gain is taxable in Canada, and roughly what is left to pay the CRA once the US tax is credited - Why the 1031 like-kind exchange your realtor keeps recommending simply does not work for Canadians - What changes when parents pass away still owning the property, from the US estate return on assets over 60,000 to a clearance certificate that can take two to three years before you can sell Resources & Links Robert M. Clegg, JD, LL.M, CanadAmerican Tax Services: canadamericantax.com FIRPTA Canada, Calgary-based FIRPTA specialists: firptacanada.com Track your days across the border with DayTracker: snowbirdsusdaytracker.com Canadians Heading South - Buy the Book: https://a.co/d/01Ryf45Z Note: the forms, thresholds, and rates discussed are general and reflect the conversation as recorded. Confirm your own situation with a cross-border tax professional and your Canadian accountant before selling.

    Episode 88: The Hidden Tax Shock: Selling Your US Property as a Canadian
  6. May 19

    Episode 87: Cross-Border Estate Planning: Wills, Exit Tax, and FIRPTA

    If you bought a place in Palm Springs or Maui twenty years ago and never thought about what happens when you sell it — or when you die — is it too late to fix that? In this episode, Gerry sits down with Kevin Kirkpatrick of Bordera Tax and Immigration Law — a dual Canadian-US lawyer based in Seattle, with his main office in Calgary — to walk through the estate planning issues that catch Canadians off guard on both sides of the border. From US estate tax thresholds to the 8-of-15 green card rule to FIRPTA withholding on US property sales, this is the conversation to have before you assume your Canadian will is enough. What You’ll Learn in This Episode Why the $60,000 US asset threshold matters — and what counts as “US stuff” when the CRA is done with you How the Canada-US Tax Treaty provides Canadian residents a pro-rated US estate tax credit, and why the current high exemption benefits most Canadians What happens when a US citizen inherits a Canadian private corporation — and why controlled foreign corporation rules create reporting obligations even for family businesses The 8-of-15 rule for green card holders: when you become a long-term resident subject to US exit tax, and a treaty exception that may reduce your exposure Why dual-licensed doesn’t mean one lawyer handles everything — and how Kevin and his partner Asim structure their practice across US and Canadian tax law FIRPTA explained: how 15% gross withholding on US property sales works, why California and Hawaii add their own layer, and what your options are Whether trusts, non-recourse mortgages, or life insurance can still help if you bought your US property decades ago without any planningResources & Links Kevin Kirkpatrick — Bordera Tax and Immigration Law: bordera.ca FIRPTA Canada (Calgary-based FIRPTA specialists): firptacanada.com Track your days across the border: snowbirdsusdaytracker.com Canadians Heading South - Buy the Book: https://a.co/d/01Ryf45Z

    Episode 87: Cross-Border Estate Planning: Wills, Exit Tax, and FIRPTA
  7. May 5

    Episode 86: What You Don't Know Will Hurt You - Gerry Scott's New Book for Canadian Snowbirds

    Guest Host: Laura Garfield | Co-Founder, Idea Decanter You’ve been heading south for years and doing everything the same way. So why does it feel like the rules keep changing? This episode is a little different. Gerry’s producer Laura Garfield flips the script and puts Gerry in the hot seat to celebrate the launch of his brand new book: Canadians Heading South for the Winters — What You Don’t Know Will Hurt You. After eight years of fielding the same snowbird questions week after week, Gerry sat down and wrote the guide he’d always wished existed. This episode is the story behind that book — what it covers, why he wrote it, and why he believes no snowbird should be without it. What You’ll Learn Why immigration and tax are two completely separate conversations — and why mixing them up is one of the most common and costly snowbird mistakes What “I’ve always done it this way” actually means at the border — and why it’s no longer a safe assumption How border agents use discretion, and why your travel pattern matters more than your intentions What happens when you’re denied entry — and why you can’t just drive to the next crossing and try again Why the book is designed as a reference guide, not a cover-to-cover read The growing trend of snowbirds selling their U.S. properties — and why it’s a taxable cross-border event most people aren’t prepared for Why Gerry split what started as one book into two — and what the second book, The Great Canadian Return, will cover Where to get your copy: http://snowbirdsheadingsouth.com/ About the Book Canadians Heading South for the Winters — What You Don’t Know Will Hurt You Gerry Scott’s debut book is a practical reference guide covering the 10 most important topics every Canadian snowbird needs to understand before heading south — immigration, tax, healthcare, residency rules, day tracking, border crossings, and more. At 180+ pages, it’s built to sit beside you, not just be read once. Available now at www.snowbirdsheadingsouth.com. Resources Get the book: http://snowbirdsheadingsouth.com/ Track your days: snowbirdsusdaytracker.com

    Episode 86: What You Don't Know Will Hurt You - Gerry Scott's New Book for Canadian Snowbirds
  8. Apr 22

    Episode 85: What Happens When You Leave Canada for the U.S.?

    What really happens to your money, your investments, and your tax obligations the moment you leave Canada for the United States? Gerry sits down with Kevin Heath of GTA Accounting to walk through what actually happens when Canadians exit Canada and become U.S. tax residents. From departure tax and deemed disposition to TFSA traps and state-level surprises, this is the conversation to have before your move becomes official on paper. • Why departure tax is triggered when you leave Canada and how deemed disposition forces you to report gains even if you have not sold anything• Which assets are included in departure tax calculations and why Canadian real estate and registered accounts are treated differently• How deferring departure tax works and when the CRA may require security before approving it• Why TFSAs lose their tax-free status in the U.S. and how mutual funds and ETFs inside them can create complex and costly reporting requirements• What PFIC rules are and why holding Canadian funds in the U.S. can trigger higher tax rates and steep penalties• How owning a Canadian corporation creates U.S. reporting obligations under Form 5471 and the penalties tied to getting it wrong• Why RRSPs are treated differently at the federal and state level and how states like California and Hawaii can tax growth inside the account• When it makes sense to liquidate investments before moving and start fresh in the U.S. with cash• How timing your move can impact whether your income or withdrawals are taxed in Canada, the U.S., or both• Why more Canadians are choosing to work in the U.S., from lower tax rates to currency advantages and broader career opportunities Resources and Links:GTA Accounting Snowbird US Day Tracker App: Available on the App Store and Google Play Coming Soon: The Snowbirds Expat Radio Book

    Episode 85: What Happens When You Leave Canada for the U.S.?

About

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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