I live in Ontario but own property in the US — does my Ontario will cover it?

Real property is generally governed by the law of the jurisdiction where it is located. If you own real estate in a US state, that property is subject to the laws of that state, including its probate and tax rules. Your Ontario will may not be sufficient — or even recognized — for purposes of transferring US property, and many US states require a separate probate proceeding (ancillary probate) for non-resident property owners.

This creates two issues: legal and tax. On the legal side, some US states will not accept an Ontario Certificate of Appointment as authority to transfer real property, requiring instead a court proceeding in that state. On the tax side, Canada and the US have an estate and gift tax treaty, but the interaction of Canadian deemed-disposition rules on death with US estate tax (which applies to non-US residents holding US situs assets above certain thresholds) is complex.

The practical options include: drafting a separate US will for US property, holding the US property in a US legal entity, or certain trust arrangements — each with different tax consequences. This is an area that requires coordinated advice from both an Ontario estate lawyer and a US-licensed attorney or cross-border tax specialist.