US federal and state estate taxes are eligible for a tax credit in Canada only because of the Canada-United State Income Tax Convention (1980). The treaty, however, does not bind Canada’s provinces. Ontario and BC, unlike other provinces, have not enacted legislation to provide a provincial tax credit for US estate taxes.
Kailey McLeod and Nadia Pulla, “Misalignment of Federal and Provincial Tax Credits” 9:4 Canadian Tax Focus (November 2019)
