BestFSBOGuide.com team
Carmen Ortiz
Americas research editor
Argentina, Brazil, Canada, Mexico and the United States. I grew up between two of them. The problem I spend the most time on is translation, because the same English word gets used for three different jobs.
English-language sources translate escribano as “notary,” and the two roles barely overlap. A US notary witnesses your signature and stamps it. An escribano drafts the instrument the registry acts on, and a Brazilian cartorio does something closer to that. If you go looking for a title company in Guadalajara you will not find one, because that function lives somewhere else.
The United States takes up the most space. Closing practice is set state by state, and so are the disclosure duties, which is why there are fifty-one state pages here and no national one. Some states run a closing through attorneys and some through escrow companies, and the seller signs different paperwork in the two.
Canada adds Quebec, which runs on civil law and uses a notaire closer to the escribano than to anything in Ontario. Provincial land transfer tax is the number I recheck most, since the thresholds move and Toronto charges its own on top of Ontario’s. Mexico adds the restricted zone along the coasts and the borders, where a foreign buyer holds through a bank trust and not in their own name.
The Brazilian ITBI is municipal, so the rate depends on the city and not on the country. Anything I write about what a sale costs in Argentina carries the date I checked it.
A little more about Carmen
Both sides of the family send me their paperwork now. They stopped asking first some years ago. Monterrey until I was nine, then San Diego, and my Spanish and English arrived in the wrong order for both school systems, so I read faster in one and argue faster in the other. I sold a house in 2016 with an agent who could not tell me what the transfer tax would come to and did not think that was strange. Two of my cousins are in construction and neither of them will read a contract before signing it. I cook on weeknights. The elevator in my building has been out since March and I am on the third floor.
Areas of focus
- US and Canadian settlement and title practice; Latin American notary and registry procedure
- Transfer taxes and capital-gains treatment, state by state and province by province
- Not Central America, not the Caribbean. Five countries is what I can keep current.
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