Michael Cirone
Michael is the founder and principal of Cirone Cross-Border Tax & Estate Lawyers. He is a senior Canadian and U.S. licensed lawyer who practices exclusively in the area of Canada/U.S. Cross-Border personal tax and estate planning for Canadians with U.S. connections.
Practice Areas:
Canada/U.S. Cross-Border Estate Planning:
- Cross-Border Wills for U.S. citizens married to Canadians, Canadian parents with U.S. citizen children or U.S. resident children, Canadians with U.S. assets, and U.S. residents with Canadian assets, including:
- Spousal Bypass Trusts for surviving spouses to protect against U.S. estate tax; and
- Dynasty Trusts for U.S. citizen children living in Canada or U.S. resident children to protect against U.S. estate tax, division of assets upon marital breakdown and third-party creditors.
- Cross-Border Alter Ego Trusts and Cross-Border Joint Partner Trusts for U.S. citizens living in Canada who are 65 years and older to eliminate Ontario probate tax and Ontario probate procedures, among the many other benefits.
Purchase of U.S. Real Estate by Canadians:
- Set up of Canada/U.S. Cross-border Trusts and Canada/U.S. Cross-border Limited Partnership structures for the purchase of U.S. real estate to protect against U.S. estate tax and personal liability.
- Restructuring of personal ownership of U.S. real estate to a Canada/U.S. Cross-Border entity ownership to achieve greater Canada/U.S. tax-efficiency.
Lifetime Gifting Strategies for U.S. Citizens and U.S. Green Card Holders Living in Canada:
- Planning and implementation of lifetime gifting strategies for U.S. citizens and U.S. green card holders living in Canada to minimize/eliminate U.S. capital gains tax on the sale of a Canadian principal residence.
U.S. Tax Planning For Expatriating U.S. Citizens And U.S. Green Card Holders:
- Tax planning for U.S. citizens/U.S. green card holders who want to expatriate from the U.S., including:
- Renouncing U.S. citizenship;
- Relinquishing a U.S. green card; and
- Minimizing or avoiding the U.S. exit tax and covered expatriate status.
Tax Planning for U.S. Residents Moving from the U.S. to Canada:
- Cross-border tax and estate planning for U.S. citizens/U.S. green card holders moving from the U.S. to Canada to maximize tax-efficiency and succession of their estate at death once permanently living in Canada.
Canada/U.S. Tax Planning for Cross-Border Inheritances:
- Minimizing or eliminating Canadian income tax for Canadian residents inheriting from a U.S. resident.
Bar Memberships:
- Ontario
- New Jersey
- Law Society of Ontario – Registered with the Law Society of Ontario as a Foreign Legal Consultant (“FLC”) authorized to provide U.S. legal advice in Ontario
Education:
- New York University School of Law, LL.M. (Master of Laws, U.S. Taxation), 2003
- Syracuse University School of Law, J.D. (Cum Laude), 2001
- University of Toronto, Hon.B.A. (with Distinction status), 1996
- Advisory Board Member, Estate Planning Council of Canada (March 2024-Present)
- Member, Estate Planning Council of Canada (May 2022-Present)
- CPA In-depth Tax Course – Parts I and II