Wealth management in Canada

“Alexis, we keep hearing there is no inheritance tax in Canada. So why is my accountant in Montreal talking about a tax due on death on assets nobody has sold?”

Canada has 119,545 French nationals on the consular register as at 31 December 2025: it is the fifth-largest destination worldwide, and one of the most stable. It is also the one where the phrase “there is no inheritance tax” does the most damage.

It is both true and misleading. Canada levies no gift or inheritance tax as such. But on death, it treats the deceased as having disposed of their assets at fair market value, and taxes the resulting capital gain. So the tax does exist; it has another name, hits another base, and is calculated on the unrealised gain built up since acquisition.

At Balmont Conseil, we treat Canada as a case with two overlapping estate tax systems — the Canadian one, which taxes a capital gain, and the French one, which taxes a transfer of wealth. The good news is that a clause in the tax treaty governs how they meet. You still need to know how to invoke it.

1. Why seek expert wealth management in Canada?

Four issues arise, and Quebec adds a further dimension.

• Two layers of tax, federal and provincial. Combined marginal rates are among the highest in the developed world, and they differ markedly between Quebec, Ontario and British Columbia. The choice of province is not neutral.
• The France–Quebec tax agreement. In addition to the federal treaty, a separate agreement of 1 September 1987 binds France and Quebec. Two texts overlap: you need to know which one applies to what.
• The deemed disposition on death. It turns real estate or business assets that have grown in value over thirty years into a taxable base in one go. It can be prepared for, notably through the spousal rollover.
• Exit tax on leaving France. Canada is one of the few countries where the deferral of payment is not automatic. This is a cash-flow constraint best discovered before the move.

2. The France ↔ Canada framework in five verified points

Here is the applicable framework, checked against official sources as at 15 September 2026. The third and fourth rows are the ones that decide your case.

Article 23 § 2 c) is the least understood point in this area. It is often said that, in the absence of an inheritance tax treaty, an expatriate in Canada suffers full double taxation. This is inaccurate: the income tax treaty, as amended in 1995, expressly deals with the case of death and provides for Canadian tax to be credited against French duties. We systematically check its application, as it often accounts for a significant share of the savings achieved on a case.

The “exit tax” row is a cash-flow constraint, not a foregone conclusion. Canada is among the countries where deferral requires an express request, a tax representative and the provision of guarantees. This has to be prepared, and it can be costed: a badly timed departure can tie up a significant sum for several years.

On arrival, Canada does the reverse and revalues the assets. Combined with the deemed disposal on leaving France, this creates a narrow window in which several decisions are far more effective than they will ever be afterwards.

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

Three workstreams, carried out in this order.

Costing the departure and the exit tax

We establish whether you cross the thresholds in Article 167 bis of the French Tax Code, and what the lack of automatic deferral means in practice: the amount of the guarantee, the form it can take, how long the funds are tied up, and the date on which tax relief is granted.

This information often changes the departure date. Either way, it is better to have it before than after.

• Assessment of unrealised gains and thresholds reached.
• Simulation of the guarantee to be provided and its carrying cost.
• Departure timetable optimised with the tax relief in mind.

Preparing the Franco-Canadian estate transfer

We model death under both systems: on one side the Canadian tax on the capital gain deemed realised, on the other the French gift and inheritance tax. We then apply the Article 23 § 2 c) deduction to arrive at the actual net cost.

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

• Modelling of death under both systems, with the treaty deduction.
• Effect of the spousal rollover and provincial probate rules.
• Costing heir by heir, according to where each one is domiciled.

Portability of savings wrappers

A French wrapper does not always follow its holder. We review, contract by contract, what can be kept, what can be switched and what should be replaced — notably with a Luxembourg assurance-vie contract, whose tax neutrality and portability were designed for this kind of move.

We do not pre-judge how Canada will treat your contract: that classification is a matter for a tax adviser licensed in Canada, and we help you put the question to them in the right terms.

4. Methodology: our way of working

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

1. The initial review. We establish your actual situation: the make-up of your wealth, the project timeline, the situation of each member of the household, and the tax domicile of your heirs — because it is theirs that counts, not yours.
2. The applicable framework. We set out, source by source and with its date, the framework that applies to you. What we do not know, we mark “to be confirmed” — never anything else.
3. The choices. We present the options with figures and their respective consequences, and you decide. Wealth structuring comes after the decision, not before.
4. Ongoing monitoring. An annual review, free of charge, to check that the framework has not moved — treaties are amended, incentive regimes are abolished, thresholds change.

5. What the firm offers you

What concretely sets our work apart.

• Sources, not claims. Every item in your file carries its reference and its date. You can check. It is the only way to work on a subject where most of the information available online is out of date.
• A single point of contact in France. We coordinate your local advisers; we do not replace them: the host country's domestic tax rules are handled with a qualified professional on the ground. Our role is to keep the whole picture consistent and to defend the French side of the file.
• Fees that are easy to understand. Fees disclosed before any commitment: fixed-price reviews, tailor-made engagements at €500 incl. VAT per hour, insurers' commissions on contracts taken out. The annual review is free of charge.

Frequently asked questions about Canada

Is it true there is no inheritance tax in Canada?

Strictly speaking, yes: no gift or inheritance tax is levied. But on death, Canada treats the deceased as having disposed of their assets at 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 is not an inheritance tax but an income tax — and that difference in nature has significant practical consequences, notably for the tax credit mechanisms.

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

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

This deduction is capped at the share of French tax relating to the assets concerned: it reduces the double charge, but does not always remove it. The calculation needs to be done precisely, and it rarely is.

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

Because automatic deferral of payment requires the host country to have agreed with France both an exchange-of-information clause and a clause on assistance in recovery. Canada has the first, but not the second as regards income tax.

As a result, deferral must be requested, and it comes with guarantees. It is a cash-flow issue, not an impossibility, but it must be anticipated.

Does Quebec change anything?

Yes, in two ways. For tax, a separate France–Quebec agreement of 1 September 1987 sits alongside the federal treaty. For estates, Quebec follows civil law, which makes some of its rules more familiar to French people — notably on 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 wealth review.

Will my French rental income still be subject to CSG?

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

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

In summary

Canada is not the inheritance-tax-free country it is sometimes described as: it is a country where that tax goes by another name and hits another base. The Franco-Canadian treaty takes this into account, through a discreet but powerful clause.

The point to watch lies upstream: on leaving France, without a clause on assistance in recovery, the exit tax requires guarantees. It is the first thing we look at.

Firm's fees: €500 incl. VAT per hour. Annual follow-up is free of charge.

Let's review your situation

A thirty-minute conversation is enough to gauge your exposure and find out whether the exit tax applies to you. You can also start with a free contract X-ray.

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