GRATs — the headline mechanic in today’s log
Does not transferA grantor-retained annuity trust arbitrages a US gift-tax valuation against a statutory IRS hurdle rate. Canada has neither. There is no federal gift tax here and no §7520 rate, so there is nothing to arbitrage — the mechanic is not harder in Canada, it is structurally absent.
It is worse than absent. Gifting appreciated property in Canada triggers a deemed disposition at fair market value, so the transfer is a taxable event to you on day one rather than a deferral. And a Canadian trust faces the 21-year deemed disposition rule, which is a clock a GRAT does not have. Reading about Selene No. 1 and Thira No. 2 is reading about a tool that does not exist in your jurisdiction.