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:

• Preparation of Cross-Border Estate Plans, Cross-Border Wills and Spousal Bypass Trusts/Dynasty Trusts to protect against U.S. estate tax, division of assets upon marital breakdown and third-party creditors for:
  • U.S. citizens married to Canadians;
  • Canadian parents with U.S. citizen or U.S. resident children;
  • Canadians with U.S. assets; and
  • U.S. residents with Canadian assets.
• Preparation of Cross-Border Alter Ego Trusts and Cross-Border Joint Partner Trusts for U.S. citizens living in Canada who are 65 years and older.

Purchase of U.S. Real Estate by Canadians:

• Cross-Border tax planning, U.S. estate tax minimization planning, liability protection planning, U.S. state probate tax minimization planning and set up of Canada/U.S. Cross-Border trust, limited partnership and corporate structures for the purchase of U.S. real estate (vacation and rental) by high-net-worth Canadians.

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. income 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 U.S. green cards
  • 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:

• Tax and estate planning for U.S. citizens/U.S. green card holders moving from the U.S. to Canada, including restructuring of U.S. assets (LLCs, U.S. revocable living trusts, U.S. non-registered investment accounts, U.S. retirement accounts) to maximize tax-efficiency once permanently living in Canada.

Canada/U.S. Tax Planning for Cross-Border Inheritances:

• Cross-Border tax planning for Canadians inheriting from a U.S. resident.
• Cross-Border tax planning for U.S. residents inheriting from a Canadian 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