Notwithstanding the very different Cdn and U.S. rules, a Canadian resident can establish a U.S. dynasty trust

“Dynasty trusts” are commonly used in the U.S. as a way to shelter transfers from U.S. generation-skipping transfer tax.

A Canadian resident on death can establish a U.S.-resident dynasty trust with exclusively U.S. residents and holding property that is not taxable Canadian property or that is exempted under Art. XIII of the Treaty. The property transferred to the trust generally has been stepped up under s. 70(5) and the trust is not deemed to be resident under the s. 94 rules once the settlor is deceased. This means that the trust will not be subject to Canadian income taxation or the 21-year deemed realization rule.

Neal Armstrong. Summary of Robert E. Ward, "Twenty-One Years Is Not Enough: Avoiding Canada's 21-Year Rule with Trusts for U.S. Beneficiaries," Tax Management International Journal, 2017, p. 710 under s. 94(5).