We just sold our DVC contract and that has been a bit of a pain so I imagine owning a place would be worse come selling time. We’ve been speaking extensively with a us based accountant to get our money back.
When a non US resident sells real estate in the USA you have to pay 20% capital gains if you make a profit. The crappy thing though is a Canadian seller has to pay a 15% Foreign investment in Real Property Tax (firpta) on the gross sale. You then file a us tax return to get the money back depending on your income.
So easy numbers, you buy property for 100k and sell for 110k. When the sale is made they automatically take 15k. Your capital gains are actually 20% of 10k so only 2000$. You have to file a tax return to get the 13k back. You can apply for a with holding certificate to hold the funds in escrow to prevent having to file a us tax return but it takes several months.
Also you need to pay capital gains in Canada as well. That is based on what the dollar was at when you paid and sold. The nice thing is you can use the tax paid in the states against what you paid in Canada.
For rentals you have to file both a us and a Canadian tax return. You only have to pay the gain once per year as the us payment can be used against your Canadian gain but again, it’s based on the dollar at the time. Our US accountant said “I don’t know much about Canadian taxes, but if you make money in the us the government wants it’s tax money” the last thing I’d ever do is piss of both the irs and cra.
I would love to own a property in the USA but it seems very complicated and would need a hefty cushion of cash flow to deal with all the fees. It’s definitely doable but more stress than we are willing to deal with.