U.S.-Canadian Tax and Estate Planning for Cross-Border...

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U.S.-Canadian Tax and Estate Planning

for Cross-Border ClientsReconciling U.S. and Canadian Law on Trusts, Deemed Dispositions

on Death, Situs Wills, and Wealth Transfers

Today’s faculty features:

1pm Eastern | 12pm Central | 11am Mountain | 10am Pacific

TUESDAY, OCTOBER 30, 2018

Presenting a live 90-minute webinar with interactive Q&A

Darren Coleman, Senior Vice President, Private Client Group, Portfolio Manager,

Raymond James, Toronto

Catherine B. Eberl, Partner, Hodgson Russ, Buffalo, N.Y.

Britta L. McKenna, Partner, Hodgson Russ, Buffalo, N.Y.

Max Reed, LLB, BCL, Tax Lawyer, SKL Tax, Vancouver, BC

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U.S.-Canadian Tax and Estate Planning for Cross-

Border ClientsCatherine B. Eberl

[email protected]

Britta L. McKenna

[email protected]

▪ Subject to estate tax on worldwide assets at death

▪ $11.18M exemption in 2018

▪ Indexed annually for inflation

▪ Increased exemption amount sunsets as of 1/1/26. Returns to $5M, indexed for inflation.

▪ 40% maximum tax rate

U.S. Persons: U.S. Estate Tax

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▪U.S. citizens or residents can transfer unused estate tax exemption to the surviving spouse

▪Must file an estate tax return at death of first spouse to elect portability

▪Under the Internal Revenue Code, portability does not apply to nonresident aliens▪ Does Treaty allow for portability?

Federal Portability

7

Assets Included in the Gross Estate:

▪ Real property

▪ Stocks and bonds

▪ Mortgages, notes and cash

▪ Certain transfers w/in 3 years of death

▪ Certain transfers with retained interests

▪ Annuities, e.g., certain retirement benefits

▪ Jointly-held property

▪ General powers of appointment

▪ Life insurance

What is Subject To Estate Tax?

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Available deductions include:

▪ Expenses of estate administration

▪ Debts of the decedent

▪ Casualty losses

▪ Charitable deduction

▪ Marital deduction

▪ State death taxes

Estate Tax Deductions

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▪ If surviving spouse is U.S. citizen, marital deduction is available for all property passing outright to the surviving spouse

▪Also applies to certain transfers in trust for U.S. citizen spouse▪ Most common: Qualified Terminable Interest Property Trust (QTIP)

▪ all income must be paid to surviving spouse

Marital Deduction

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▪ If surviving spouse is not a U.S. citizen:

▪ There is no marital deduction for property passing to spouse outright

▪ Qualified Domestic Trust (QDOT) is the only way to claim marital deduction

▪ Stringent administration rules

▪ All income must be paid to surviving spouse

▪ Must have a U.S. Trustee

Marital Deduction Cont’d

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▪Subject to U.S. estate tax only on U.S. situs assets at death▪ U.S. real property

▪ U.S. tangible personal property

▪ U.S. stocks▪ Includes stocks held in an RRSP

▪ $60,000 exemption

▪Greater relief available under U.S. / Canada Treaty

NRAs: U.S. Estate Tax

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▪Estate Tax Returns

▪ Estate of U.S. citizens and U.S. residents file Form 706▪ Required if adjusted gross estate in excess of exemption in effect in year of

death, or if electing portability

▪ Estate of non-citizens, non-residents file Form 706-NA▪ Required if U.S. situs assets in excess of $60,000 in year of death

▪ Both are due nine months from date of death

▪ May request automatic six month extension (for a total of 15 months)

▪ BUT, the estate tax due must be paid at the nine month mark

Estate Tax Filing Deadlines

13

Beware of State Level Estate Tax Returns, Too

▪ Was decedent domiciled in a U.S. State with estate tax?

▪ Or, did decedent own real property in a U.S. State with estate tax?

▪ States deadlines may be different that federal deadlines ▪ Connecticut returns are due 6 months after death

Estate Tax Filing Deadlines Cont’d

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▪U.S. citizens & U.S. residents

▪ Assessed on gratuitous transfers of worldwide assets during life


▪ Unlimited marital deduction for gifts to U.S. citizen spouse

▪ Exemptions & exclusions

▪ $15,000 annual gift tax exclusion per donee (2018)

▪ $152,000 annual gift tax exclusion for gifts to non-citizen spouse (2018)

▪ $11.18M lifetime gift tax exemption. Sunsets as of 1/1/26 and returns to $5M, indexed for inflation. Unified with estate tax exemption.

U.S. Gift Tax

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▪NRAs

▪ Assessed on gratuitous transfers of U.S. situs assets during life

▪ U.S. real property

▪ U.S. tangible personal property


▪ Unlimited marital deduction for gifts to U.S. citizen spouse

▪ Exemptions & exclusions

▪ $15,000 annual gift tax exclusion per donee (2018)

▪ $152,000 annual gift tax exclusion for gifts to non-citizen spouse (2018)

U.S. Gift Tax

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▪Beware of unintentional gifts when:

▪ transferring property between U.S. spouse and Canadian spouse

▪ transferring U.S. situs property between Canadian spouses

U.S. Gift Tax

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▪Gift Tax Returns

▪ U.S. citizens and U.S. residents file Form 709

▪ Non-citizens, non-residents file Form 709

▪ Due April 15th of the year following the year of the gift

▪ May request automatic six month extension (for a total of 15 months)

▪ BUT, any gift tax must be paid at the nine month mark

Gift Tax Filing Deadlines

18

Cross-Border Estate Planning

Max Reed LL.B, BCL

SKL Tax

[email protected]

+1 604 732 1515

ABOUT MAX REED

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Max is a cross-border tax lawyer. He assists clients with tax problemsthat span the US/Canada border with a particular emphasis on UStaxation for Canadian corporations, trusts, and individuals.

Max has written widely on the topic of cross-border taxation. He co-wrote a book on the taxation of US citizens in Canada and wrotenumerous technical tax articles (one of which one an award from theCanadian Tax Foundation) and a series of columns for the National Post.He is regularly invited to speak on cross-border tax issues includingconferences organized by the Canadian Tax Foundation, the New YorkSociety of CPAs, and Democrats Abroad Canada. He was also invited totestify before the Canadian House of Commons Finance Committee onthe impact of US tax law on Canadians.

Prior to joining SKL, Max worked at White & Case LLP, an internationallaw firm in New York City where he provided US tax advice toindividuals, corporations, and foreign states. He holds a BA and two lawdegrees from McGill University and is admitted to the bars of BC andNew York.

Max can be reached at:

[email protected] or 604-732-1515 x 221

mailto:[email protected]

Canadian Taxes at Death

[email protected]

+1 604 732 1515

• Canada has a capital gains tax at death –rates differ by province of residence but in the 24-27% range

• E.G. - you buy a share of Apple for $5 and at the time you die it is worth $15 = $10 of capital gains

• Different tax base for Canadian tax residents and non-residents

• Also worth noting:– Taxation of RRSPs

– Charitable donations

– Canadian resident executor

CANADIAN INCOME TAX AT DEATH

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• Deemed disposition applies to worldwide assets

• Principal residence is exempted from tax

• Spousal rollover defers tax until death of second spouse (ITA 70(6))

• Complex estate planning for corporations

– Be careful when beneficiaries are US taxpayers or decedent was US taxpayer

DEEMED DISPOSITION - RESIDENTS

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• Deemed disposition at death but limited to “Taxable Canadian Property” (TCP)

• TCP definition (248(1)) is somewhat complex, but includes:– Real property

– Certain corporations that own real property

– Canadian resource property

– Income interest in Canadian trust

– Life insurance

• Rollover to spouse available under the Treaty

DEEMED DISPOSITION – NON-RESIDENTS

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• During lifetime, tax deferred in both Canada/US under Canada-US Tax Treaty

• Canada – at death Can tax deferred to spouse or disabled child

• Taxable when second spouse dies

• Designate beneficiaries of RRSPs to avoid probate

• For US residents with RRIFs/RRSPs – designate Canadian beneficiaries – only 25% tax at death

RRSPs/RRIFs

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• Bequests to charity can reduce capital gains and estate tax at death

• Gifts to both Canadian and US charities can reduce US federal estate tax

• Gifts to US colleges/universities that the donor or donor’s family attended are fully creditable against Canadian capital gains tax

• Canadian tax benefit for gifts to other US charities is limited to 75% of US source income

• Best strategy is to give to Canadian charities

CHARITABLE GIVING

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• One common trap is for Canadians to have a sole non-Canadian resident executor

• This can cause tax problems with the estate• US based executor may have problems with

Canadian estate• Better to have estate managed from Canada – even

if executors are joint• Other option → do all the mind and management

while physically located in Canada even if beneficiaries non-residents

CANADIAN ESTATES = CANADIAN EXECUTOR

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• Final T1 is due April 30 of year following unless date of death is November 1 – December 31 in which case 6 months after death

• T3 return for income earned by the estate• March 31

FILING DEADLINES

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1. Pro-rated estate tax credit

▪U.S. provides an estate tax credit for non-citizen Canadian residents with U.S. situs property:

▪ Equal to U.S. credit, but prorated based on ratio of U.S. situs assets to worldwide assets

▪Must file Form 706 or 706-NA to claim the credit, even if no tax is due

Treaty Credits: Estate Tax

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2. U.S. Estate Tax Marital Credit for Property Left to a Surviving Spouse

Amount:

▪ If decedent was a U.S. citizen▪ Marital credit is an amount equal to the U.S. estate tax credit (which currently

equals a $11.18M exemption, meaning that a total of $22M can be transferred to the surviving spouse)

▪ If decedent was not a U.S. citizen, but a Canadian resident ▪ Credit is equal to the prorated estate tax credit allowed to non-citizens under the

treaty

U.S. / Canada Income Tax Treaty Marital Credit

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Eligibility:▪ Property would have qualified for U.S. estate tax marital deduction

if the surviving spouse were a U.S. citizen;

▪ Decedent must have been a U.S. citizen, or resident of U.S. or Canada;

▪ Surviving spouse is a resident of U.S. or Canada;

▪ If decedent and SS were both U.S. residents at time of decedent’s death, then one or both must have been Canadian citizens; and

▪ Executor elects to use the treaty credit and waives the marital deduction (most likely scenario, Executor uses the treaty credit and forgoes QDOT option)

Treaty Credits: Estate Tax

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Credits providing relief from double taxation:

▪ Canadian income tax credit ▪ Available to estate of Canadian resident for U.S. federal and state estate tax due

on U.S. situs property

▪ U.S. estate tax credit▪ Available to estate of U.S. citizen or U.S. resident for the Canadian federal and

provincial income taxes payable in Canada on account of deemed disposition at Decedent’s death on property situated outside the U.S.

▪ Credit is computed under Internal Revenue Code as if it were a credit for foreign death taxes

▪ If treaty credit is claimed, cannot claim the Canadian taxes as a deduction or credit under any other part of the Code

Treaty Credits

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▪ Review terms of Canadian trusts for U.S. estate tax inclusion▪ Relevant if there is a U.S. beneficiary or U.S. Trustee, or if trust owns U.S. situs property

▪ Consider how assets are held between U.S. citizen spouse & non-citizen spouse

▪ If U.S. spouse dies first, consider how to qualify for U.S. marital deduction or treaty marital credit

▪ If non-U.S. spouse dies first, consider U.S. spouse inheriting in trust

▪ Consider how to take title to U.S. situs assets

▪ Separate Wills for U.S. situs property?

U.S. Estate Tax Planning Considerations

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Cross-Border Trusts and Taxes

[email protected]

+1 604 732 1515

• Canada and the US have very different trust rules

• A trust taxed one way in one country may be taxed the other way in the other country

• No time to go through all trust rules – instead hit some conceptual highlights of different scenarios

• There is no treaty tiebreaker for trusts

• Very common scenario: – client goes to advisor in one country sets up trust

– Beneficiaries are in other country

– Advisor fails to see cross-border perspective

– Problems!

TRUST INTRODUCTION

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• American sets up revocable trust moves to Canada → trust is now Canadian tax resident → compliance misery

• Canadian sets up US revocable trust to own US real estate:– No US estate tax protection

– Possible Canadian capital gain on settling

– No basis bump at death in Canada

– 21 year rule exposure in Canada (not US)

– Double tax risk on rental income

COMMON TRUST TRAPS

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• Canadian tax resident is beneficiary of US revocable trust –> no cost basis bump in Canada (discussed later)

• Canadian resident sets up testamentary trust for US beneficiary:– Trust is likely a foreign non-grantor trust for US tax

purposes

– Accumulated income subject to “Throwback” tax on distribution (very expensive + complex)

• US beneficiary of Canadian trust that owns CANCO shares → Punitive US tax result (PFIC)

COMMON TRUST TRAPS (2)

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• Canadian beneficiary of US trust with no Canadian contributor and mind and management in the US– Tax free distributions for Canadian tax purposes if

income is earned in one year and paid in the next year to Canadian resident

– Allocate DNI using 65 day rule in for US tax purposes

– Allocate capital gains to have them not taxed in the US trust

– Pay attention to make sure trust qualifies and that beneficiary has not right to the income otherwise trust will not qualify

TRUST OPPORTUNITIES

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• US beneficiary of Canadian trust with a foreign grantor

– Make non-US person the grantor of the trust so that no US tax to recipient

– Foreign grantor is limited under IRC 672(f) but if trust is “revocable” can qualify

– ”Revocable” defined in regulations as trustee having reversionary interest in income and capital

– Discretionary Canadian trust will often qualify;

– No TOSI to US beneficiary; no PFIC, no CFC

– Plan to get distributions to US resident beneficiary at 15/25% total tax (Canadian withholding rate – unclear)

TRUST OPPORTUNITIES (2)

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• Many US residents use a revocable trust to avoid probate

• Assets in these trusts will have an increased cost basis in the US because the US ignores the trust

• Canada does not give you an increase in basis– Mom bought a cottage for US$100,000

– Put it in a revocable trust in the US

– Mom dies and the cottage is worth US $250,000

– Months later, trustee sells the cottage for US $260,000

– US $10,000 in taxable capital gain for US tax purposes

– But in Canada US $160,000 in taxable capital gain

CANADIANS AND US GRANTOR TRUSTS

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• Don’t use probate avoiding trusts in the US where there are Canadian beneficiaries

• Use a will instead

• Sell assets in one year and distribute them in the next year– No Canadian tax on distributions

• Make the trust establish Canadian tax residency → cost basis bump in Canada → make sure compliance is done properly– T3

– NR4 slips for distributions to US beneficiaries

– 1041

– K-1

– Should be no Canadian withholding if US source income

PLANNING

42The basics of estate planning for dual citizens| Max Reed | [email protected]

ESTATE FREEZE WITH US BENEFICIARIES

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• Assume kids have moved to the US

• Potential implications

– US children indirectly own Alpha Inc. • Application of US anti-deferral regime (PFIC/CFC)

• Increase tax cost of dividends

• Investment income imputed to kids

– FT may be foreign non-grantor trust

• Throwback rules may increase tax cost of distributions

IMPLICATIONS

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• Remove US taxpayer as beneficiary; do not distribute

• Manage application of anti-deferral regime in first year kids receive distributions

• Distribute UNI to non-US resident; then distribution to US resident

• Ensure that FT is a foreign grantor trust– Specific drafting and analysis is required

– Blocks US anti-deferral regimes

– Trust distribution is a gift in the US

SOLUTIONS

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• US citizen plans estate with US revocable trust

• Puts all investments in it

• Moves to Canada

• Forgets to shut down revocable trust

• Compliance headache – Canadian tax resident due to mind and management

• No Treaty Tiebreaker

• Forms are expensive to do

AMERICAN MOVES TO CANADA WITH US TRUST

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• Make sure revocable trust is shut down prior to move to Canada

• Once in Canada, do VDP on trust filings to mitigate penalties

• Watch out for Canadian 21 year deemed disposition rule

• Look at whether revocable trust is exempt from filings as mere agency agreement under ITA 104(1)

– Complex and aggressive position

SOLUTIONS

47

WHY RAYMOND JAMES (USA) LTD?

Due to the demand for cross-border financial services, Raymond James has created

Raymond James (USA) Ltd. – a US-registered investment firm established to serve the

unique needs of these investors.

Along with giving US resident investors access to Canadian financial markets, we

support Canadians living in the US and Americans living in Canada with a single point of

contact and counsel for their registered and non-registered accounts.

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WHAT WE DO

▪ Through Raymond James (USA) Ltd., clients have the ability to hold both Canadian and US

investments in either Canadian dollars or US dollars, thus avoiding foreign exchange spreads.

▪ Advice on both Canadian and US securities. We are properly licensed and regulated in both

countries.

▪ A single point of contact for Canadian-held RRSPs, US-held IRAs, US-dollar investments, and

Canadian dollar investments.

• Assistance in dealing with cross-border issues, such as Blue Sky laws, stock underwritings, and

currency transfers.

• Full access to the Canadian and US fixed income universe.

▪ Raymond James maintains research teams in Toronto, Calgary, Vancouver, and throughout the

US.

▪ We also maintain professional networks to assist with taxation and legal questions.

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Customized and Integrated financial planning with a Quarterly Roadmap

to chart and track progress towards your goals, including:

• Retirement income planning projections

• Retirement cash-flow analysis, including RRIF, IRA, annuity, LIF, LRIF and pension accounts

• Advanced tax planning for high-income executives, professionals and entrepreneurs

• Education planning (RESPs in Canada)

• Estate, trust & succession planning

• Risk management analysis, including life, disability, critical illness reviews

• Long term care analysis and coverage

PROMODULE PROCESS ~ ADVANCED FINANCIAL PLANNING

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Choice of Discretionary & Non-Discretionary Portfolio Management

• A fully tailored investment program for you and your family

• Incorporating best-in-class investment products and outstanding research

• Taking advantage of prudent and sophisticated investment structures for smoother performance

• Focused on risk management and after-tax returns

SOPHISTICATED INVESTMENT MANAGEMENT

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Unique capabilities of our Pershing LLC is our “back office”

• Member of every major US securities exchange

• Access to Deutsche Borse, Irish Stock Exchange and the London Stock Exchange, among others

• Access real-time inventory of fixed income products from more than 90 dealers in the US

• Tap into premium research tools from the most respected third-party content providers

• Monitor current interest rates, money fund rates, commodity prices and stock and option indices

• Facility to handle and trade in multiple global currencies

ROBUST & INTERNATIONAL TRADING PLATFORM

AED UAE Dirhan ARS Argentine Peso AUD Australian Dollar BDT Bangladesh Taka

BGN Bulgarian Lev BMD Bermudian Dollar BRL Brazilian Real CAD Canadian Dollar

CHF Swiss Franc CLP Chilean Peso CNY Chinese Renminbi

(Offshore CNH) COP Colombian Peso

CZK Czech Koruna DKK Danish Krone EGP Egyptian Pound EUR Euro

GBP British Pound HKD Hong Kong Dollar HRK Croatia Kuna HUF Hungarian Forint

IDR Indonesian Rupiah ILS Israeli Shekel INR Indian Rupee ISK Iceland Krona

JPY Japanese Yen KRW South Korean Won LKR Sri Lanka Rupee LTL Lithuanian Litas

LVL Latvian Lats MAD Moroccan Dirham MUR Mauritius Rupee MXN Mexican Peso

MYR Malaysian Ringgit NAD Namibia Dollar NOK Norwegian Krone NZD New Zealand Dollar

PEN Peruvian New Sol PHP Philippine Peso PKR Pakistani Rupee PLN Polish Zloty

RON New Romanian Leu RUB Russian Ruble SEK Swedish Krona SGD Singapore Dollar

THB Thailand Baht TRY New Turkish Lira TWD Taiwan Dollar USD US Dollar

VEF Venezuela Bolivar

Fuerte ZAR South African Rand ZMK Zambian Kwacha ZMW Zambian Kwacha

54

RAYMOND JAMESAT-A-GLANCE• A leading North American independent full-service

investment firm with an extensive presence in key centres

in Canada.

• Raymond James Financial was founded in 1962 and has

been a public company since 1983 (NYSE-RJF).

• Our market capitalization today is US$12 billion.

• Raymond James provides financial services through three

wholly-owned investment firms: Raymond James &

Associates, Raymond James Financial Services and

Raymond James Ltd.

• We serve individual, institutional investors, and

corporations.

RAYMOND JAMES AT-A-GLANCE

55

IN CANADA• Raymond James Ltd. now sits at over 1,400 employees and

agents in Canada, including 494 financial advisors.

• Our private client assets under administration total C$45

billion.

• With corporate offices in Vancouver and Toronto, we have

124 branches in Canada.

We leverage the full strength of Raymond James through:

• Our Powerful North American Platform

• Strong Canadian Leadership

• Independent and Unbiased Advice

• Breadth of Products and Services

• State-of-the-art Technology and Service

Capabilities.


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ACCOLADES AND ACHIEVEMENTS

• Raymond James Financial moves up in the Securities/Asset Management category of FORTUNE magazine’s World’s Most

Admired Companies list for 2017.

• In December 2017, Raymond James raised $968,381 for over 400 charities across Canada through its Annual Giving Campaign.

• In September 2016, Raymond James Ltd. welcomed 3Macs to the family, creating Canada’s largest independent dealer.

• In June 2016, Raymond James Financial was added to the Fortune 500, having achieved a record revenue of $5.20 billion in 2015.

• In 2016, the Thomson Reuters Analyst Awards bestowed four awards on our equity research team for stock picking and estimating

earnings. Our team has received several of the StarMine/Thomson Reuters awards since 2004.

• Our equity research team ranked 7th in the 2016 Brendan Wood Canadian Equities report. Four of our analysts, two institutional

sales people, and two institutional traders were recognized for their work.

• Raymond James is one of Canada’s Top 100 Employers for 2017.

• Raymond James has been proud to be the lead sponsor for Prostate Cancer Foundation BC’s Father’s Day Walk/Run since 2015.

Approximately $700,000 has been raised since 2015 to support critical prostate cancer research, support groups, and programs for

cancer survivors.


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The American in Canada

Kathryn & Margaret - One spouse moved to Canada and the other spouse is Canadian citizen

Issues to consider

• Managing 401k/IRA

• Managing RRSP

• Managing non-registered US accounts/CDA accounts

• Investment product selection and compliance with PFIC

• Cash flow management in two currencies

• When to take CPP and Social Security

• Various Pensions and conversion to LIF and IRA

• Variable Annuities in USD

• Estate planning

• US estate taxes

• Canadian taxes

• Choice of Executor

CASE STUDIES

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The American in Canada

Jim – Starting his 5 year rotation as the Canadian CFO for a US-based multinational pharmaceutical company.

Issues to consider

• Threat of closure of his IRA and brokerage accounts by his US financial institution

• Use of RRSP to mitigate Canadian taxes

• Managing non-registered US accounts from Canada



• Integrating CPP and Social Security entitlements

• Estate planning

• US estate taxes

• Canadian taxes

• Choice of Executor while in Canada and upon return to the USA

CASE STUDIES

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The Canadian in America

Paul - Pursuing a new career, new opportunities and a relationship in the US for a global bank.

Issues to consider

• Establishing 401k/IRA

• Managing RRSP

• Managing non-registered US accounts/CDA accounts



• When to take CPP and Social Security

• Various Pensions and conversion to LIF and IRA

• Variable Annuities in USD

• Estate planning

• US estate taxes

• Canadian taxes

• Choice of Executor

CASE STUDIES

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Cross-border Estates & Trusts

Fraser – Toronto resident acting as Trustee of his deceased Uncle’s revocable trust in Florida.

Issues to consider

• Reluctance or inability for US Financial institutions to work with a Canadian resident

(also same problem in reverse)

• Investment product selection

• Taxation of a US trust

CASE STUDIES

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Inherited IRA’s

Chris & Julie – Canadian children of a deceased parent in the US.

Issues to consider

• 5 children were appointed beneficiaries of Mom’s IRA

• 3 children live in the US and two live in Canada

• All were to be treated equally by their mother in the will

• American resident children are eligible for a rollover to an “Inherited IRA” which provides

5 years of tax deferral

• Canadian children were not able to open an “inherited IRA” at any US financial

institution, as they reside in Canada and Canadian FI’s do not offer IRA’s as they are an

American retirement vehicle.

• We were able to obtain Tax Identification Numbers (TIN) for each Canadian resident

beneficiary and then open Inherited IRA’s for them. They are now treated equally as their siblings.

CASE STUDIES

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DARREN COLEMANFINANCIAL ADVISOR, FINANCIAL ADVISOR

RAYMOND JAMES (USA) LTD.

ANDREA THOMPSONSENIOR FINANCIAL PLANNER

ASSOCIATE FINANCIAL ADVISOR

VIKKI BROWNFINANCIAL PLANNER

PEDRO OSTIA-VEGASENIOR FINANCIAL ADVISOR ASSISTANT

NIK ZABALJAC

FINANCIAL ADVISOR ASSISTANT

Suite 1902 – 200 King Street West

Toronto, ON

M5H 3T4

T: 416.777.7158 • 1.877.363.1024

[email protected]

www.colemanwealth.com

MEMBER OF FINRA/SIPC

64

mailto:[email protected]

http://www.colemanwealth.com/

Raymond James (USA) Ltd. (RJLU) prepared this presentation. Information is from sources believed to be reliable but

accuracy cannot be guaranteed. It is for informational purposes only. It is not meant to provide legal or tax advice; as

each situation is different, individuals should seek advice based on their circumstances. Nor is it an offer or solicitation

for the sale or purchase of securities. It is intended for distribution only in those jurisdictions where RJLU is registered.

RJLU, its officers, directors, employees and families may from time to time invest in the securities in this presentation.

Securities offered through Raymond James (USA) Ltd., Member-FINRA/SIPC

DISCLAIMER

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