June 11, 2025

(PASADENA, CA) – KJMLAW Partner Andrew Nutbrown joined Kevin Bemel, of The Bemel Group’s Trusts & Estates Weekly podcast to talk about international estate planning.

Since 2022, Nutbrown has focused his practice on trust administration and estate planning with KJMLAW Partners. Previously, he worked as an attorney focusing on wills and estates with Doyle Prendergast in Canada.

Check out a snippet of Andrew’s interview with Kevin Bemel, or watch the full interview here.

KB: Hello and welcome to Trust and Estates Weekly I’m your host Kevin Bemel and we’re here every Monday at 10:00 a.m. pacific time to talk about estate planning and trust and estate administration both from the standpoint of professionals like my guest Andrew Nutbrown and me but also for you know individuals who are faced with this particular financial challenge. Always good to sort of peek in and get some thoughts about what has to happen in order to make sure that our own financial our own estate plan is put together and we’re taking care of ourselves which you know you it always brings up the cliche of the estate planning lawyer who has no trust, has no has no will…right, typical thing so we’re going to try and avoid that. So, as I mentioned just a moment ago, I’m really pleased to have as my guest today Andrew Nutbrown. So, Andrew is a an estate planning and estate administration attorney here in the Los Angeles area; you’re based up in Pasadena right? Yep that’s right yeah and you will you will sense right away that Andrew speaks with a little bit of an accent; that’s because he comes from the land of – this is the only Canadian thing I know – the land of twofers, which I’m told refers to a 24 pack of beer which is I guess how Canadians buy beer. So now you know the full extent of my knowledge of Canada other than Montreal is an extraordinarily beautiful city and I loved every minute that I spent there lo these many years ago. So, Andrew is going to be talking about cross border estate issues, which I think is a topic we haven’t covered here on the show yet. So, Andrew, welcome to Trusts and Estates Weekly, thanks for joining the show. So let’s get to the topic now which is cross border estate issues. You mentioned that you know a lot of your work at least in the beginning was cross border Canada you know US what do what do you see as being the most common cross border issues with which you have to deal and why are those you know why do those do you think those come up you know so frequently?

AN: So there’s a lot of Canadians in general down in California – the snowbirds like it down here – so I think I see it in commonly in two different forms: either a U.S. person that that lives down here is U.S. citizen and has either like a cottage or some assets in Canada, and then the second is a Canadian resident or Canadian citizen and then they have like a vacation home in California or they just have assets generally in the U.S. so those are the two I would say most common types of scenarios and they have very unique issues and different issues… I would say maybe a third one would be their parents or grandparents are in Canada and they’re now living in the U.S. and they’re expecting to inherit a lot of assets from Canada and so they reach out because they want to see okay how can this best be done right and similar scenarios in other countries as well. But for Canada, those are the kind of the three things I see and it gets really interesting because then you get presented with a unique puzzle that you have to try to make fit and I always describe it as in Canada you’ve got um circular pieces in the US you have square pieces and you have to just make the best puzzle you can in that in that circumstance  

KB: You know, it’s interesting, I realized as you were talking just now I have a longstanding friend originally from Canada – British Columbia, to be specific – and this is now going back I think about 3 four years ago… her father had passed away, he lived in Canada, she’d been a longtime resident here in Los Angeles, had a business career here and everything, and I think she had become a U.S. citizen and her father had left behind a house in British Columbia right but he also had a house in in Arizona, and you know the going back and forth and dealing with it all it was really kind of frazzling her nerves right along with, of course, she was the only child. So that you know, again, having she her mother had passed away many years before but now her father to whom she was very close had died, and it was just the whole emotional burden of it was very difficult.

AN: Yes, so like, in that circumstance, if they’re living down here, Canada is generally tax based on residency so in that situation the only asset in Canada that would get hit after passing would be the assets situated in Canada and located in Canada like the real property or stocks and bonds or shares in Canadian corporations that hold real property. So because of that, like in Canada, there’s no estate tax like there is in the U.S.

###