US & Canadian Shares
Expert support for US and Canadian shareholdings
What we do
Dealing with US and Canadian shares can be time-consuming and complicated. Different rules, strict documentation requirements, and long timescales can all slow down the estate administration process.
We help you navigate these challenges with clarity and confidence.
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We can help:
Verify the current status of a shareholding directly with a US or Canadian Transfer Agent, e.g., to confirm current ownership, the number of shares held, whether it is held in certificated or electronic format, and provide a date of death valuation in line with HMRC guidelines.
Validate whether the certificates held are valid.
Transfer ownership of a holding and arrange for dividends to be reissued. This includes completing all relevant US forms, such as transfer paperwork, Affidavit of Domicile, W-8BEN, and W-8BEN-E forms, as well as obtaining a Medallion Signature Guarantee.
Arrange the sale of a holding post-transfer to remit funds to the UK estate – we complete all relevant paperwork, including stockbroker forms.
Apply to the IRS to gain tax certification for a holding when US assets form part of a UK estate and exceed $60,000, the output of which is a Federal Transfer Certificate or Form 5173
Advise on escheated assets and raise claims with the relevant State Office to claim funds on behalf of the estate
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If the UK estate includes assets held in the United States, you may need tax clearance from the IRS.
This usually applies when the total US estate value exceeds $60,000 at the date of death. In these cases, the IRS may require a Federal Transfer Certificate (Form 5173) before the assets can be transferred.
There is a tax treaty in place between the US and the UK to help prevent double taxation. This means that if the deceased was UK domicile at the time of death and was not a US citizen or resident of the US during their lifetime, they won’t need to pay tax twice on the same assets. However, this does not remove the need for tax clearance as US financial institutions will need the correct documents before allowing the release or transfer of assets.
The current timeframe to obtain tax clearance from the IRS is around two to three years.
Important to know
Not all US financial institutions will request tax clearance. However:
All US Transfer Agents require it, and
Many investment management companies will also request it
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If a US asset remains inactive for a period of time, it may be classed as dormant.
After three to five years, a US asset can become dormant and pass to State ownership. Once this happens, an asset is often liquidated and the resulting funds are held on an unclaimed asset register held by the state.
An asset may be considered dormant when there is no activity on the account. This can include:
No contact from the account holder
No changes to a registered address
No additional investment activity, such as purchasing shares
Dividends that remain unclaimed
If the account holder has died, it can be difficult to maintain activity. This increases the risk of escheatment.
Escheatment can create several complications, such as:
You may not be able to confirm the value of the assets
The timing of liquidation is controlled by the state
The original asset no longer exists once it has been sold
Once liquidated, the asset cannot increase or decrease in value. Only the recovered funds remain.
This is why it’s important to act as soon as possible if the estate has US assets.
If however, the assets have already escheated we can help you recover what is owed to the estate, so beneficiaries receive their rightful inheritance.
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A Medallion Signature Guarantee is an anti-fraud measure used when transferring US or Canadian shareholdings. It confirms that the signatures on transfer documents are genuine. In probate cases, this usually applies to the Executor or Administrator of the estate.
Without a Medallion Signature Guarantee, US paperwork can be rejected. This can delay the administration process.
If you are transferring ownership of US or Canadian shares, you will need the guarantee, and it must:
Be applied to the transfer forms
Include a security limit in US dollars ($)
Cover the full value of the shares being transferred
If the limit is too low, the forms will not be accepted.
Title Research can arrange Medallion Signature Guarantees quickly and efficiently. We have access to guarantees with limits of:
$500,000
£1,000,000
These limits cover most estate administration scenarios involving US and Canadian shares. We guide you though the process and ensure everything is in place, so you can avoid unnecessary delays.
Why choose Title Research
You don’t need to coordinate multiple providers or manage unfamiliar processes. We bring everything together in one place, including:
Federal Transfer Certificate applications
Medallion Signature Guarantees
Escheatment recovery
Share transfer support
This joined-up approach saves you time and reduces the risk of delays.
We help you avoid unnecessary delays
Some processes, such as IRS tax clearance, can take two to three years. We help you identify what is required early on. This allows you to plan ahead and keep the estate moving wherever possible.
Our experience means we can anticipate challend=ges before they arise.
How it works
What is a Medallion Signature Guarantee?
A Medallion Signature Guarantee is an anti-fraud measure that acts to verify that the signatures on various forms required to administer US or Canadian shareholdings are genuine. For probate purposes, this will usually relate to the signatures of an Executor or Administrator.
Requirement for U.S. and Canadian share transfers
When transferring ownership of a US or Canadian shareholding, the transfer forms must be appended with a Medallion Signature Guarantee, or the forms will be rejected. Additionally, the Medallion must have a security limit in US dollars ($) that will cover the holding value that is being transferred.
Available up to $500K/£1M
Title Research has access to Medallion Signature Guarantees with a $500,000 and £1,000,000 limit, which can cover most common scenarios.
Plan with Purpose
When we deliver, it’s not just a finished product—it’s a solution you can trust, backed by real care and effort.
What we need
To obtain a Medallion Signature Guarantee, we would require the following as a minimum:
Proof of ownership (such as a DRS statement or dividend advice letter) – ideally, dated within six months
A copy of the Grant of Probate or Letters of Administration
A certified copy of the Personal Representative’s passport
A certified copy of a Personal Representative’s utility bill or bank statement – dated within three months
Case Study: Resolving complicated Canadian shareholdings
A Solicitor instructed Title Research to sell two Canadian shareholdings as part of an estate she had been administering.
She had been trying to complete the sale for eight years and was keen to resolve the matter before retiring.
The case was complicated. The shares were held in the joint names of three individuals, two of whom had already died. Each of the deceased had appointed four Executors, meaning nine individuals needed to be involved in the process. To add further difficulty, the original share certificates were missing.
We worked closely with the Solicitor to guide her through each stage. We explained the process clearly and ensured all instructions were included with the paperwork.
Throughout the matter, we provided regular updates every two weeks, supporting the coordination of nine signatories. Once documentation had been completed, we arranged for the missing share certificates to be reissued. We then progressed with the sale of the shares.
We completed the entire process in just nine months.
This brought the matter to a close after years of delay. The Solicitor was able to retire with confidence, knowing the estate had been fully administered.
Get started
Our expert team can help you meet any estate administration challenge.
If you require help with US and Canadian shares, complete the form with a few details. We'll review your enquiry and get back to you within 48 hours.