Wealth Management in Canada

«"Alexis, we keep being told that there are no inheritance taxes in Canada. So why is my accountant in Montreal talking about a tax payable upon death on assets that no one has sold?"»

Canada is home to 119,545 French citizens registered with the consular registry as of December 31, 2025: this is the fifth most popular destination in the world, and one of the most stable. It is also the one where the phrase "there are no inheritance taxes" causes the most damage.

It is both accurate and misleading. Canada does not actually levy any inheritance tax. However, upon death, it considers that the deceased has arranged of his assets at their fair market value, and he taxes the resulting capital gain. The tax therefore does exist; it has a different name, a different tax base, and is calculated on the unrealized capital gain accumulated since the acquisition.

At the house of Balmont Conseil, We treat Canada as a case involving two overlapping inheritance tax systems—Canadian, which taxes capital gains, and French, which taxes inheritances. The good news is that a clause in the treaty governs their convergence. The challenge lies in knowing how to invoke it.

1. Why seek expertise in wealth management In Canada?

Four issues arise, and Quebec adds an additional dimension.

• The dual tax system, federal and provincial. Combined marginal tax rates are among the highest in the developed world, and they differ significantly between Quebec, Ontario, and British Columbia. The choice of province is not neutral.
• The France-Quebec tax agreement. In addition to the federal agreement, a separate agreement from the 1^er September 1987 links France and Quebec. Two texts overlap: it is necessary to know which one applies to what.
• The presumed disposition upon death. It transforms real estate or business assets appreciated over thirty years into taxable assets all at once. It is prepared for, in particular, by transferring ownership to a spouse.
• Exit tax when leaving France. Canada is one of the few countries where payment deferral is not not Automatic. This is a cash flow constraint that is best discovered before the move.

2. The France ↔ Canada framework in five verified points

Here is the applicable framework, verified in official sources as of September 15, 2026. The third and fourth lines are those that determine your case.

Article 23 § 2 c) is the least known aspect of this case. It is often claimed that, in the absence of a succession agreement, an expatriate in Canada is subject to full double taxation. This is incorrect: the Income Tax Convention, as amended in 1995, expressly addresses the situation of death and provides for the crediting of Canadian tax against French inheritance tax. We systematically verify its application, as it often represents the most significant portion of the savings achieved in a case.

The "exit tax" line item is a cash flow constraint, not an inevitability. Canada is among the countries where a stay of execution requires an explicit request, a tax representative, and the provision of guarantees. This requires preparation and cost considerations: a poorly timed departure can tie up a significant sum of money for several years.

Upon arrival, Canada applies a reverse revaluation of the assets. Combined with the deemed disposition upon departure from France, this creates a narrow window where several trade-offs become far more effective than they will ever be again.

3. Our services: 360° support for expatriates and investors

Three projects, carried out in this order.

Calculation of departure and exit tax

We establish whether you cross the thresholds of article 167 bis of the general tax code, and what the absence of automatic deferment concretely represents: amount of the guarantee, form it can take, duration of immobilization, date on which the relief takes place.

This information often changes the departure date. In any case, it's better to have it before rather than after.

• Evaluation of unrealized capital gains and thresholds reached.
• Simulation of the guarantee to be established and its carrying cost.
• Departure schedule optimized with regard to the tax relief.

Preparation for the French-Canadian transmission

We model the death under both systems: on the one hand, the Canadian deemed capital gains tax, and on the other, the French inheritance tax. We then apply the deduction under Article 23 § 2 c) to obtain the actual net expense.

We cross-reference this result with Article 750 ter of the French General Tax Code (CGI), paragraph 3 of which makes all assets received by an heir domiciled in France for at least six of the last ten years taxable in France. The result therefore depends as much on your children's domicile as on your own.

• Modeling of death in both systems, with conventional deduction.
• Effect of spousal rotation and provincial homologation rules.
• Calculation of heirs by heir according to each heir's residence.

Portability of savings accounts

A French envelope does not always remain with its holder. We examine contract by contract what is retained, what is subject to arbitration, and what is replaced—particularly by a Luxembourg life insurance contract, whose tax neutrality and portability were designed for this type of journey.

We do not prejudge the Canadian treatment of your contract: this qualification falls under the jurisdiction of a tax specialist authorized in Canada, and we help you to ask them the question in the appropriate terms.

4. Methodology: our way of working

We work in four stages, and you know where you are at each stage.

1. The initial assessment. We assess your actual situation: composition of assets, project timeline, situation of each member of the household, and tax domicile of your heirs — because it is theirs that dictates, not yours.
2. The applicable reference framework. We establish, source by source and with its date, the framework that concerns you. What we do not know, we write "to be confirmed" — never anything else.
3. The arbitrations. We present you with the numerical options, along with their respective consequences, and you decide. Heritage engineering comes after the decision, not before.
4. The follow-up. An annual review, offered free of charge, which verifies that the framework has not changed — the conventions are modified, the attractiveness schemes are eliminated, the thresholds change.

5. What the firm offers you

This is what specifically distinguishes our intervention.

• Sources, not claims. Each item in your file has its reference number and date. You can check. This is the only way to work on a subject where most of the information available online is outdated.
• A single point of contact in France. We coordinate with your local advisors, we do not replace them: the internal tax regulations of the host country are handled by a qualified professional on site. Our role is to maintain overall consistency and to defend the French side of the case.
• Fees that are easy to understand. Firm fees: €500 including VAT per hour. Annual follow-up is included. No hidden kickbacks, no performance-based billing.

Frequently Asked Questions in Canada

Is it true that there are no inheritance taxes in Canada?

That's correct in the strictest sense: no gift tax is levied. However, upon death, Canada considers that the deceased disposed of their assets at their fair market value and taxes the corresponding capital gain in the deceased's final tax return.

On assets held for a long time, the bill can be substantial. It's not an inheritance tax, it's an income tax — and this difference in nature has significant practical consequences, particularly on the mechanisms for offsetting tax credits.

Will I be taxed twice, in Canada and then in France?

Not entirely. Article 23 § 2 c) of the convention of 2 May 1975, as amended by the 1995 amendment, provides that France deducts from its inheritance tax an amount equal to the Canadian tax paid on the gains taxable in Canada on the occasion of death.

This deduction is capped at the proportion of French taxes related to the assets in question: it reduces the cumulative effect, but does not always eliminate it. The calculation should be done precisely, and it rarely is.

Why is the exit tax more restrictive for Canada than for other countries?

Because the automatic deferral of payment requires that the host state has concluded with France both an information exchange clause and a recovery assistance clause. Canada has the former, but not the latter, with regard to income tax.

Consequently, a deferment must be requested, and it comes with guarantees. It's a cash flow issue, not an impossibility, but it must be anticipated.

Is Quebec changing anything?

Yes, for two reasons. On the tax front, a France-Quebec agreement separate from the 1^er September 1987 was added to the federal convention. In matters of inheritance, Quebec falls under civil law, which makes some of its rules more familiar to a French person — particularly regarding notarial wills.

In practice, your province of residence affects both your marginal tax rate and the cost of settling your estate. We take this into account from the initial assessment.

Will my French rents still be subject to CSG?

Yes, at the full rate of 17.2 %. The exemption from CSG and CRDS is reserved for persons affiliated to a compulsory scheme of a State of the European Economic Area, Switzerland or the United Kingdom.

The social security agreement between France and Canada, like the agreement with Quebec, coordinates pension rights. It does not grant this exemption.

In summary

Canada is not the country without inheritance tax that it is sometimes portrayed as: it is a country where this tax goes by another name and is levied on a different basis. The Franco-Canadian convention takes this into account through a discreet but powerful clause.

The key point of concern lies upstream: when departing from France, in the absence of a recovery assistance clause, the exit tax requires guarantees. This is the first thing we look at.

Firm's fees: €500 including VAT per hour. Annual follow-up is offered.

Let's review your situation

A thirty-minute exchange is enough to assess your exposure and determine if the exit tax applies to you. You can also start with a Free X-ray of your contracts.

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