Cross-Border Tax Compliance Checklist: Canada and US

Cross-border tax compliance is two income tax returns plus the information forms that ride along with them: accounts, funds, companies and trusts in the other country each bring their own form, and most have their own threshold. Which ones you owe depends on what you are: a US citizen in Canada, a Canadian who moved to the US, a Canadian with US income, or a Canadian corporation with US ties. The checklist below is built that way, for the 2026 tax year filed in 2027. For every date in more detail, see cross-border tax filing deadlines.

The 2026 tax year checklist

Dates are for a calendar-year individual or corporation filing for 2026, and they match our deadline guide. “With the return” means the form is attached to that return and shares its due date, including extensions. Thresholds and who-files rules are in the sections after the table.

Filer	Form	Who files it	Due for 2026	Read next
US citizen in Canada	T1	Every Canadian resident who must file	April 30, 2027 (June 15 if self-employed; pay by April 30)	US citizens in Canada
US citizen in Canada	Form 1040 (with Form 1116 for Canadian tax)	Every US citizen required to file, wherever they live	June 15, 2027 automatic while abroad; October 15, 2027 with Form 4868; tax due April 15, 2027	Same
US citizen in Canada	FBAR (FinCEN 114)	US persons whose foreign accounts top $10,000 combined at any time	April 15, 2027, automatic extension to October 15, 2027	FBAR requirements
US citizen in Canada	Form 8938	Above $200,000 at year end or $300,000 at any time (single, living abroad)	With the 1040	Form 8938 vs FBAR
US citizen in Canada	Form 8621	Shareholders of a PFIC (many Canadian mutual funds and ETFs are), one form per fund	With the 1040	Canadian funds and PFICs
US citizen in Canada	Form 5471	US persons with a reportable interest in a Canadian corporation, for example control above 50%	With the 1040	Form 5471 for a Canadian corporation
US citizen in Canada	Form 3520 / 3520-A	Gifts over $100,000 from a nonresident alien individual, or a foreign trust	3520: June 15, 2027 if abroad, extended with the return; 3520-A: March 15, 2027	Deadline guide
US citizen in Canada	T1135	Canadian residents with foreign property costing over $100,000, such as a US brokerage account	With the T1	T1135 guide
Canadian who moved to the US	Final T1 for the year you left	You, for the departure year	April 30 of the year after you leave	Departure tax
Canadian who moved to the US	Form 1040, FBAR, Form 8938, Form 8621	You, as a US resident with Canadian accounts and funds	1040: April 15, 2027; FBAR as above; 8938 and 8621 with the 1040	Form 8938 vs FBAR
Canadian who moved to the US	NR4 slips	Your Canadian payers, on income subject to Part XIII tax	Payer gives you the slip by March 31, 2027	Deadline guide
Canadian with US income only	T1, plus T1135 if over $100,000 of US property	You, as a Canadian resident	April 30, 2027; T1135 with the T1	T1135 guide
Canadian with US income only	W-8BEN	You, to each US payer	Renew by December 31 of the third year after signing	W-8BEN vs W-8BEN-E
Canadian with US income only	Form 1040-NR, Form 8840	You, with US business or rental income, a refund to claim, or a closer-connection claim	June 15, 2027 if no US wages (April 15 with US wages); 8840 by the 1040-NR due date	Form 1040-NR for Canadians
Canadian corporation (CCPC)	T2	The corporation	June 30, 2027 (six months after a December 31 year end)	W-8BEN-E guide
Canadian corporation (CCPC)	W-8BEN-E	The corporation, to each US payer	Renew by December 31 of the third year after signing	Same
Canadian corporation (CCPC)	Form 1120-F	A Canadian corporation with US business income or a treaty position to protect	June 15, 2027 with no US office; April 15, 2027 with one	Can a Canadian own a US business
Canadian corporation (CCPC)	T1134	A Canadian resident (corporation or individual) with a foreign affiliate, such as a US subsidiary	10 months after year end: October 31, 2027	Same
Canadian corporation (CCPC)	NR4 slips and Part XIII tax	The corporation, when it pays dividends to a non-resident shareholder	NR4 by March 31, 2027	Deadline guide

October 31, 2027 is a Sunday, so for the T1134 we’d file by the Friday before, as the deadline guide explains. Payments run on their own calendar: the last 2026 US estimated payment is January 15, 2027, and Canadian instalments for individuals are March 15, June 15, September 15 and December 15.

What does a US citizen living in Canada file?

Both countries’ returns every year: the IRS says a citizen living abroad is “subject to tax on worldwide income,” and as a Canadian resident you file a T1 too. On top of the T1 and the 1040, the US side adds an FBAR once your non-US accounts pass $10,000 combined, and often Forms 8938, 8621 and 5471. Canada adds the T1135 when you hold over $100,000 of property outside Canada.

The dates: the CRA’s due dates page sets April 30 for the T1 and June 15 “if you or your spouse or common-law partner are self-employed,” with payment still due April 30. For the 1040, the IRS page for citizens abroad gives “an automatic 2-month extension” to June 15, then “an additional extension to October 15 by filing Form 4868,” and warns “you will have to pay interest on any tax not paid by the regular due date.” The Canadian tax you pay generally comes across as a credit on Form 1116.

The information forms each have their own trigger:

• FBAR. The IRS FBAR page says a US person must file to report “a financial interest in or signature or other authority over at least one financial account located outside the United States if the aggregate value of those foreign financial accounts exceeded $10,000 at any time during the calendar year reported.” FinCEN’s due date notice sets April 15 with “an automatic extension to October 15 each year.”
• Form 8938. For a single filer who meets the presence-abroad test, the 8938 instructions set the threshold at “more than $200,000 on the last day of the tax year or more than $300,000 at any time during the tax year,” and $400,000 or $600,000 for a joint return.
• Form 8621. The 8621 instructions say “A separate Form 8621 must be filed for each PFIC,” and to “Attach Form 8621 to the shareholder’s tax return.”
• Form 5471. A Category 4 filer is “a U.S. person (defined below) who had control (defined below) of a foreign corporation,” meaning more than 50% of the vote or value, per the 5471 instructions. Other categories catch smaller stakes. You “Attach Form 5471 to your income tax return.”
• T1135. CRA’s T1135 questions and answers say it “must be filed on or before the due date of the taxpayer’s income tax return,” and the threshold is a total cost amount of more than $100,000 at any time in the year.

What does a Canadian who moved to the US file?

A final Canadian return for the year you left, then US returns as a US resident: Form 1040 by April 15 each year, an FBAR for the Canadian accounts you kept, and Forms 8938 and 8621 when their thresholds and triggers are met. On the Canadian side, your payers withhold non-resident tax and send NR4 slips.

The departure-year T1 follows the regular April 30 date on the CRA’s due dates page, which also says the filing due date “is April 30 for most non-residents.” The IRS when-to-file page gives April 15 for the 1040, and an extension “gives you until October 15 to file,” but “Make sure you pay any tax you owe by the April filing date.” The June 15 automatic extension is for people living outside the US, so it no longer applies once you’ve moved.

Two thresholds change with the move. A US-resident single filer’s 8938 threshold drops to “more than $50,000 on the last day of the tax year or more than $75,000 at any time during the tax year.” And the T1135 stops: CRA says only taxpayers resident in Canada file it. On the income side, CRA’s guide T4061 says “Non-residents have to pay a 25% tax on amounts that are taxable under Part XIII,” reduced where the treaty allows, and payers send NR4 slips “on or before the last day of March.”

What does a Canadian with US income file?

A Canadian resident with US income files the usual T1, gives each US payer a W-8BEN, and files a US Form 1040-NR only when there’s US business or rental income to report, a refund to claim, or a closer-connection statement to attach. If US property costs more than $100,000 in total, the T1135 comes due with the T1.

The W-8BEN generally stays valid until “the last day of the third succeeding calendar year” after signing, per the W-8BEN instructions, so a form signed in 2026 runs through December 31, 2029. The 1040-NR instructions set the date: “If you didn’t receive wages as an employee subject to U.S. income tax withholding, file Form 1040-NR by the 15th day of the 6th month after your tax year ends,” which is June 15, 2027 for 2026, and April 15 if you had US wages. Snowbirds attach Form 8840 to that return, or mail it “by the due date (including extensions) for filing Form 1040-NR” if there’s no return. Which W-8 to sign, and why never a W-9, is in W-8BEN vs W-8BEN-E vs W-9.

US rent is the case that most often needs a 1040-NR. Publication 515 says the payer must withhold on US rents “unless the foreign payee elects to treat this income as effectively connected with a U.S. trade or business,” in which case the payee gives the payer Form W-8ECI and reports the rent on a return.

What does a Canadian corporation with US ties file?

Its T2 within six months of year end, a W-8BEN-E for each US payer, and, depending on the facts, a US Form 1120-F, a T1134 for any US subsidiary, and NR4 slips for dividends paid to a non-resident owner. A US citizen who owns the corporation files Form 5471 on their own 1040.

CRA’s T2 due date page says to file “by the last day of the sixth month after the end of the tax year” when the year ends on the last day of a month, so June 30, 2027 for a December 31, 2026 year end. The 1120-F instructions set “the 15th day of the 6th month after the end of its tax year” for a foreign corporation without a US office or place of business, and the 4th month for one with an office. ITA 233.4(4) requires the T1134 “within 10 months after the end of the year or period,” from a reporting entity, meaning “a taxpayer resident in Canada … of which a non-resident corporation is a foreign affiliate.”

Whether a Canadian company needs a US return at all turns mainly on whether it has a permanent establishment in the US, covered in can a Canadian own a US business. The W-8BEN-E, line by line, is in the W-8BEN-E guide for Canadian corporations.

What are the most common cross-border tax issues?

The issue that comes up most is a missed information form. For a US citizen in Canada it’s usually the FBAR, Form 8621 on Canadian funds, or Form 5471 on their own company. For a Canadian with US income, it’s signing a W-9 instead of a W-8BEN. For a Canadian company, it’s US income with no W-8BEN-E on file.

Each has a fix that starts with the right form: US citizens in Canada covers the full US-side list, Form 8938 vs FBAR sorts out the overlap, and Canadian funds and PFICs explains which Canadian funds are PFICs and need a Form 8621. If years have already been missed, the dates in the deadline guide tell you what’s late now.

This guide is general information, not tax advice for your specific situation. Which points apply, and how, depends on your facts.