CRA indicates that there are no barriers to a non-resident estate qualifying as a GRE

The U.S.-resident estate of a U.S.-resident individual who died holding real estate in Canada and did not have a social insurance number (“SIN”) will realize a gain on the disposition of the property. CRA indicated that the definition of graduated rate estate (GRE) does not require an estate to be resident in Canada, and that the requirement in para. (c) of the GRE definition to provide the SIN of the deceased, or “such other information as is acceptable” can be satisfied by the estate providing a temporary or individual tax number.

Neal Armstrong. Summary of 7 June 2019 STEP CRA Roundtable, Q.10 under s. 248(1) - graduated rate estate – para. (c).