Michael Cirone US Canada Tax Lawyer

Michael Cirone, Hon.B.A., J.D., LL.M. (NYU), Foreign Legal Consultant in Ontario (U.S. Law)

Email: michael.cirone@taxchambers.ca

Tel: 647-748-9797

Michael Cirone | Canada/U.S. Cross-border Tax and Estate Planning Lawyer

Michael Cirone has been a tax lawyer since 2001. He is a Canada/U.S. cross-border tax, trust and estate planning lawyer and is licensed to practice law in both Ontario and the U.S. Additionally, Michael is licensed by the Law Society of Ontario as a Foreign Legal Consultant to provide U.S. legal advice in Ontario, which is a requirement for all Ontario lawyers who provide advice on foreign law. Michael’s extensive knowledge and experience with tax, trust and estate planning law in both Canada and the U.S., enables him to provide his clients with seamless Canada/U.S. cross-border advice.

Michael’s practice focuses on tax, trust and estate planning for people and businesses crossing the Canada/U.S. border and the preparation of all of the legal documents required both in Canada and in the U.S., making his practice a one-stop shop for the cross-border client and eliminating the need to retain multiple lawyers on both sides of the border.

Before joining TaxChambers LLP, Michael was the partner in charge of another Toronto tax boutique law firm’s Canada/U.S. Cross-border Tax and Estate Planning Group. Before that, Michael practiced as a tax lawyer for a mid-sized full-service law firm in Toronto and as a tax lawyer for one of the Big Four Accounting firms in New York City.

Practice Areas

Below are some examples of the types of Canada/U.S. cross-border areas that Michael frequently advises on and implements:

For Canadian People and Canadian Businesses

(1) Purchase and sale of U.S. real estate by Canadians.
(2) Canadian departure tax and US pre-immigration planning for Canadians moving to the U.S.
(3) Cross-border tax planning for Canadians moving back to Canada from the U.S., including personal tax issues and the tax-efficient reorganization of their worldwide entities (companies, partnerships and trusts).
(4) Expansion of Canadian businesses to the U.S.
(5) Purchase of existing U.S. businesses by Canadians.
(6) Cross-border tax planning for Canadians providing services in the U.S.

For US People and US Businesses

(1) Expansion of U.S. businesses to Canada.
(2) Investment in Canadian real estate by U.S. taxpayers.
(3) Purchase of existing Canadian businesses by U.S. taxpayers.
(4) Cross-border tax planning for U.S. citizens/U.S. residents moving to Canada from the U.S., including personal tax issues and the tax-efficient reorganization of their worldwide entities (companies, partnerships and trusts).
(5) Cross-border tax planning for US residents providing services in Canada.
(6) Irrevocable life insurance trusts (ILITs) for U.S. citizens and U.S. residents to hold life insurance policies.

Canada/U.S. Cross-border Estate Planning

(1) Cross-border estate planning (including the preparation of Wills and Powers of Attorney) for:

  • Canadians married to Americans (living in Canada or in the U.S.);
  • Americans married to Americans, but living in Canada;
  • Canadian parents with U.S. citizen/U.S. resident children; and
  • U.S. residents with Canadian assets.

Canada/U.S. Cross-border Trusts

(1) Set up of cross-border trusts.
(2) Advice regarding U.S. beneficiaries of Canadian trusts.
(3) Advice regarding Canadian beneficiaries of U.S. trusts.

Canada/U.S. Cross-border Reorganizations

(1) Cross-border Canada/U.S. reorganizations of entities (companies, partnerships, trusts) to effect more tax-efficient structures.

Cross-border Entity Set-up

(1) Set up of Canadian and U.S. companies, partnerships and trusts. Michael can implement structures on both sides of the border so his clients do not have to hire separate Canadian and U.S. lawyers…making his practice a one-stop shop for clients.

Education

  • LL.M. (U.S. Tax), New York University School of Law, 2003
  • J.D. (Cum Laude), Syracuse University School of Law, 2001
  • Hon.B.A. (with Distinction Status), University of Toronto, 1996
  • CICA (now CPA Canada) In-depth Tax Course Parts I & II, 2005-2007

Certifications

  • Foreign Legal Consultant Permit granted by the Law Society of Ontario to provide U.S. legal advice in Ontario

Memberships

  • Law Society of Ontario
  • Canadian Tax Foundation
  • American Bar Association

Bar Admissions

  • Ontario
  • New Jersey