Q: I’m trying to get to the bottom of whether or not CDRs are considered U.S.-situs property for Canadian citizens/residents who don’t otherwise have any U.S. connection (other than through their stock market investments). If one checks the CDR website (https://cdr.cibc.com/#/contact), there is the following statement: “The application of U.S. federal estate tax to CDR holders is dependent on an individual’s particular circumstances and CIBC does not provide tax advice. As such, CDR holders should consult their own tax advisors regarding the U.S. federal estate tax consequences of investing in the CDRs.” I have never seen any “official” document on any website that provides a clear answer. Are you aware of anything “official” out there that is definitive in this regard? I am looking for a definitive source (reference) that can be cited in this regard. (And please make the assumption when addressing this question that the Canadian account holder in question would have sufficient overall assets that they would be subject to U.S. estate taxes, if indeed CDRs for U.S. corporations are indeed considered to be U.S.-situs assets.) (I realize you are not tax experts/advisors, but this does seem to be a rather basic issue that must somewhere have a clear cut "official" answer.)
Ted
Ted