CRA considers in the GRE context that a deceased has one estate even if an offshore will is unknown to the domestic executors

CRA’s position respecting the graduated rate estate rules, that there is only one estate, which encompasses all of the world-wide property of the deceased, applies even where the executors of a domestic will are not even aware of the existence of a second will pertaining to the deceased’s foreign assets. CRA noted that this very well could give rise to problems, without getting granular.

Neal Armstrong. Summary of 10 June 2016 STEP Roundtable, Q. 2 under s. 248(1) - graduated rate estate.