Plain-English guides on US and Canadian tax, cross-border moves, bookkeeping, and running a small business. Written by a dual-licensed CPA.
US businesses hiring Canadian contractors do not issue a 1099 when the contractor provides a W-8BEN. The W-8BEN replaces the W-9, claims the treaty exemption, and eliminates withholding on business profits performed from Canada.
Cross-BorderAmericans can buy property in Canada, but a federal ban on foreign purchases of residential property runs through January 1, 2027. Even where the ban does not apply, provincial taxes for foreign buyers add 20-25% to the purchase price in BC and Ontario.
Cross-BorderIf you were born outside Canada to a Canadian parent, you may already be a Canadian citizen. Bill C-3 (in force December 2025) removed the first-generation limit for those born before December 15, 2025. Claiming Canadian citizenship does not by itself create a Canadian tax obligation, but moving to Canada or opening Canadian accounts does.
Canadian TaxA CCPC is a private corporation resident in Canada that is not controlled by non-residents or public companies. CCPC status unlocks the small business deduction (9% federal rate on the first $500,000 of active business income), the lifetime capital gains exemption on share sales, and the refundable tax mechanism on investment income.
Canadian TaxRepresent a Client is the CRA's online portal that lets authorized representatives access a taxpayer's account. You authorize a representative through My Account, by phone, or by submitting Form AUT-01 (formerly T1013). Authorization levels range from view-only to full disclosure and account changes.
Canadian TaxA deemed disposition is a tax event where the CRA treats you as having sold property at fair market value even though no actual sale occurred. It triggers on death, emigration, trust anniversaries, gifts, and change of use, creating a capital gain (or loss) that you must report.
Cross-BorderUS citizens in Canada file two returns but rarely pay two full tax bills. The foreign tax credit, the FEIE, and the Canada-US treaty each prevent a different slice of double taxation. Here is where they work, where they fail, and what you actually owe.
Cross-BorderThe Canada-US tax treaty has been in force since 1984, preventing double taxation and setting which country taxes each type of cross-border income. It reduces withholding rates, allocates taxing rights, and has been updated five times by protocol.
Cross-BorderA US Employer Identification Number (EIN) is the American equivalent of a Canadian Business Number. Canadian companies that operate in the US, hire US employees, or file US tax returns need one. The application is Form SS-4, and the fastest route from Canada is a phone call.
Canadian TaxA family trust is an inter vivos trust used for income splitting, estate planning, and asset protection. It is a taxable entity with a December 31 fiscal year-end, subject to the 21-year deemed disposition rule, and must file a T3 return annually.
Cross-BorderFATCA requires foreign banks worldwide to report accounts held by US persons to the IRS. It also requires US persons to report their foreign financial assets on Form 8938, making it the dual-sided enforcement mechanism behind offshore compliance.
Cross-BorderForm 708 is the IRS return for reporting gifts and inheritances received from a covered expatriate. US persons who receive more than the annual exclusion amount from someone who renounced citizenship or gave up a green card and triggered covered expatriate status must file Form 708 and may owe a 40% tax on the transfer.
Cross-BorderForm 8938 is the IRS form for reporting specified foreign financial assets under FATCA. Filing thresholds depend on where you live and how you file. The form covers foreign accounts, foreign securities, and interests in foreign entities, with penalties starting at $10,000 for failure to file.
Canadian TaxCanada has no gift tax. Cash gifts are not taxable to the giver or the recipient. But gifting property (stocks, real estate, a business) triggers a deemed disposition at fair market value, so the giver may owe capital gains tax even though nothing was sold.
Cross-BorderThe IRS generally has three years from the date you filed to assess additional tax. That extends to six years when you omit more than 25% of gross income. There is no time limit at all for fraud, willful evasion, or unfiled returns.
Canadian TaxCanada has no inheritance tax, but the deceased's terminal return pays income tax on deemed capital gains at death. Provinces also charge probate fees on estate value. The heir receives assets tax-free while the estate bears the cost before distribution.
Cross-BorderThe tax side of moving from the US to Canada, from the planning year through your first Canadian return. Residency triggers, dual filing, foreign tax credits, and the accounts that cause trouble.
Cross-BorderThe physical presence test qualifies you for the FEIE by requiring 330 full days in a foreign country during any 12 consecutive months. Full days run midnight to midnight, the period can start on any date, and days over international waters do not count.
Cross-BorderCanada has no retirement visa, so you need permanent residence or a family connection to stay. Your Social Security follows you, but so does the US tax return. Healthcare kicks in once you have PR status. Here is the full picture.
Canadian TaxIn Canada, most trusts are irrevocable once assets are transferred. A revocable trust triggers attribution rules and offers no tax benefit. An irrevocable trust enables income splitting, creditor protection, LCGE multiplication, and probate avoidance when the settlor gives up all control.
Cross-BorderAn RRSP is Canada's tax-deferred retirement account, functionally similar to a US 401(k) or traditional IRA. When you leave Canada, the account stays open, withdrawals are subject to Canadian withholding, and the US taxes the income with a credit for the Canadian tax.
Cross-BorderA side-by-side comparison of the RRSP and 401(k) for people who have lived in both Canada and the US. Contribution rules, tax treatment, transfer mechanics, and which account to prioritize when you hold both.
Cross-BorderA Section 962 election lets a US individual pay the 21% corporate rate on CFC income instead of rates up to 37%. It also unlocks indirect foreign tax credits for Canadian corporate tax already paid, which typically eliminates the US tax bill entirely for Canadian corporation owners.
Cross-BorderSubpart F income is the original US anti-deferral rule for controlled foreign corporations. It taxes certain passive and mobile income of a CFC currently to the US shareholders, even if the corporation does not distribute it. For US persons who own Canadian corporations, the most common trigger is foreign personal holding company income.
Canadian TaxThe T1135 is required when your specified foreign property exceeds $100,000 CAD at any point as a Canadian resident. The penalty for missing it starts at $25 per day, and the cost amount, not market value, is what triggers the filing.
Cross-BorderBoth the TFSA and the Roth IRA let you invest after-tax dollars and withdraw tax-free. The structural similarities end at the border: a TFSA creates a foreign trust problem for US persons, and a Roth IRA needs a treaty election in Canada.
Cross-BorderThe Canada-US income tax treaty allocates taxing rights between the two countries and prevents double taxation. It covers dividends, interest, pensions, employment income, capital gains, and business profits, with specific rates and rules for each category.
Cross-BorderA US citizen can visit Canada for up to six months without a visa, but living there permanently requires a work permit or permanent residence. The tax side starts the day you arrive: you keep filing US returns and add a Canadian return on top.
Cross-BorderThe step-by-step tax checklist for Americans moving to Canada, from pre-move planning through the first dual-country filing. RRSP election, TFSA warning, FBAR trigger, investment cleanup, and the forms that start on arrival day.
Canadian TaxYou can hold US stocks in a TFSA, but 15% US withholding tax on dividends sits inside the account with no credit to recover it. Where US-dividend stocks belong in your account lineup depends on your marginal rate and the dividend yield.
Cross-BorderA US client or payer asked you for a W-9, but you live in Canada and are not a US person. The W-9 is for US taxpayers. Canadians provide Form W-8BEN (individuals) or W-8BEN-E (entities) to certify foreign status and claim treaty-reduced withholding.
Cross-BorderYour 401(k) stays in the US when you move to Canada, and you can leave it to grow, take distributions, or transfer it to an RRSP. Each option carries different tax consequences on both sides, and the ITA 60(j) deduction is what makes the RRSP transfer work.
Canadian TaxAn RRSP (Registered Retirement Savings Plan) is a tax-deferred retirement account in Canada. Contributions are tax-deductible, growth is tax-free inside the plan, and withdrawals are taxed as income. The contribution limit is 18% of prior-year earned income, up to $32,490 for 2025.
Cross-BorderNo departure tax (you're not leaving Canada, you're arriving), but US filing obligations follow you permanently. FBAR from day one, PFIC on Canadian mutual funds, TFSA as a likely foreign trust, and RRSP only works with the treaty election.
Cross-BorderThe Canada Child Benefit is tax-free in Canada but counts as foreign-source income on a US return. In practice, the foreign tax credit and treaty provisions eliminate any additional US tax, so the question is how to report it correctly.
Cross-BorderCanadian rates are higher at most income levels, but comparing headline rates is misleading. The real comparison includes provincial tax, state tax, sales tax, healthcare costs, and credits that differ between the two systems.
Cross-BorderTechnically yes, but it creates PE risk, US payroll tax obligations, and state tax nexus for the employer. The cleaner options are a US entity, a contractor arrangement, or an employer of record, because the compliance burden catches most Canadian employers off guard.
Cross-BorderA Canadian employer pension paid to a US resident faces Canadian Part XIII withholding and US income tax. The treaty rate is 15% for periodic payments, and the FTC prevents double taxation, but the treatment differs from CPP and OAS in ways that matter at filing time.
Cross-BorderFiling a W-8BEN stops the default 30% US withholding on payments to a Canadian freelancer. The treaty makes business profits taxable only in Canada when there is no US permanent establishment, so the correct rate is zero.
Cross-BorderThe US withholds on the distribution (30% default, reduced to 15% under the treaty for periodic payments). Canada taxes the full amount as income but gives you a credit for the US withholding. The distribution may also qualify for the ITA 60(j) deduction if you roll it into an RRSP.
Cross-BorderWhen a Canadian trust has a US-resident beneficiary, the US can tax distributions at the highest marginal rate plus interest. The accumulation distribution rules under IRC 665-668 add a deemed deferral charge that shocks beneficiaries who expected the trust to shelter income.
Cross-BorderThe CRA VDP allows taxpayers to correct errors or omissions on prior Canadian returns without full penalties. Since the 2018 overhaul, the program has two tracks: the general track (Track 1, limited relief) and the wash transaction track (Track 2, no-name pre-screening).
Cross-BorderAlimony is deductible by the payer and taxable to the recipient in Canada. In the US, post-2017 agreements made alimony non-deductible and tax-free. When one spouse is in Canada and the other in the US, this mismatch creates planning opportunities and traps.
Cross-BorderDividing RRSPs, 401(k)s, IRAs, and pensions in a cross-border divorce triggers treaty, withholding, and rollover rules that domestic divorces do not face. The wrong transfer can create immediate taxation in both countries.
Cross-BorderCanadian estate planning techniques interact with US estate tax, gift tax, and trust rules in ways that create double taxation. Estate freezes, alter-ego trusts, joint partner trusts, and testamentary trusts each carry cross-border traps that require coordination.
Cross-BorderCanada and the US follow different rules on medical expense deductions, and a cross-border bill may be claimable in one country, both, or neither. The METC and IRC 213 differ on what qualifies, what threshold applies, and how foreign-paid expenses are treated.
Cross-BorderEvery disposal is a taxable event in both countries, but the cost basis, inclusion rate, and reporting forms are different. Canadian exchanges trigger FBAR. US exchanges trigger T1135. And the cost basis lives in two currencies.
Cross-BorderIf you hold both citizenships but have always lived in one country, you still have filing obligations in the other. The US taxes citizens worldwide regardless of residence. Canada taxes residents regardless of citizenship. The obligations are permanent and annual.
Cross-BorderF-1 students are exempt individuals for five calendar years, so their days don't count toward the substantial presence test. OPT doesn't reset the clock. Once the exemption expires, residency can start mid-year.
Cross-BorderIn Canada, the foreign tax credit (Form 1116) almost always beats the Foreign Earned Income Exclusion (Form 2555). The FEIE sounds like a shortcut, but in a high-tax country it wastes the excess credits you would otherwise carry forward.
Cross-BorderYes, under IRC 6013(g), a US citizen or resident can elect to treat a non-resident alien spouse as a US resident for filing purposes. The election gives you MFJ brackets and the standard deduction, but it subjects your Canadian spouse's worldwide income to US tax.
Cross-BorderThe credit is limited to the US tax on your foreign-source income, not the full Canadian tax you paid. When that Canadian tax later changes, IRC 905(c) forces a redetermination, and missing the notification can trigger its own penalty.
Cross-BorderUsually yes. The FBAR goes to FinCEN when foreign accounts top $10,000 in aggregate. Form 8938 goes to the IRS with your return when foreign assets cross a higher threshold that depends on where you live and how you file.
Cross-BorderMoving to the US does not automatically cancel your GST/HST registration. If you still make taxable supplies in Canada, the registration stays. Whether those supplies qualify for zero-rating depends on the place-of-supply rules and the recipient's location.
Cross-BorderCanadians who need to file a US tax return but do not qualify for a Social Security Number apply for an ITIN using Form W-7. The process involves mailing your passport or using a Certifying Acceptance Agent, and the application must accompany a valid tax return.
Cross-BorderThe NR4 reports Canadian-source income paid to non-residents and the Part XIII tax withheld. On the US return, the income goes on the appropriate schedule (pension, dividends, interest, rental), the withholding generates an FTC on Form 1116, and all amounts are converted to USD.
Cross-BorderYou can, but your broker may not let you trade. Most US brokerages restrict nonresident accounts once you update your address to Canada. The tax side is workable if you stick to US-listed investments and report the accounts to the CRA.
Cross-BorderThe 3.8% NIIT under IRC 1411 applies to US citizens in Canada, and the foreign tax credit often cannot offset it. The NIIT is a separate tax that does not participate in the regular FTC mechanism, so Canadian tax on the same investment income may not help.
Cross-BorderNo. Under Article XVIII(1) of the Canada-US tax treaty, OAS paid to a US resident is taxable only in the US. Canada cannot claw back benefits that are not taxable in Canada.
Cross-BorderWhen you become a non-resident of Canada, payers of Canadian-source income must withhold Part XIII tax at 25% (reduced by treaty). This applies to pensions, RRSP/RRIF withdrawals, dividends, interest, rents, royalties, and management fees.
Cross-BorderUS-listed ETFs and individual stocks are safe from PFIC classification, but Canadian mutual funds and Canadian-listed ETFs are not. This guide covers what a US citizen in Canada can hold without triggering the punitive Form 8621 regime.
Cross-BorderWithout a QDOT, the unlimited marital deduction does not apply to transfers to a non-citizen spouse. The estate tax can hit at the first death instead of being deferred, and the treaty credit is the alternative route when a QDOT is not practical.
Cross-BorderThe RDSP does not travel well across the border, because moving to the US means losing the Disability Tax Credit and triggering a grant repayment. The US may also treat the plan as a foreign trust, adding Forms 3520 and 3520-A to your filing stack.
Cross-BorderWhen a US-based contractor provides services in Canada, the Canadian payer must withhold 15% of the gross payment under Regulation 105. The withholding can be reduced or eliminated with a treaty-based waiver, but you must apply before the work is performed.
Cross-BorderThe tax answer depends on your income mix, province, state, and whether you value OAS clawback avoidance, healthcare coverage, or estate tax simplicity. There is no universal winner.
Cross-BorderConverting to a Roth before moving to Canada triggers US tax now but can avoid Canadian tax on withdrawals later. The Article XVIII(7) election is what makes it work, and getting the timing wrong means paying tax in both countries on the conversion.
Cross-BorderWhen RSUs vest after a cross-border transfer, both countries' payroll systems may withhold independently. The combined withholding often exceeds the actual tax owed, and while the excess is recoverable, the cash flow impact is immediate and the reconciliation is not simple.
Cross-BorderThe timing of a business sale relative to your move determines the LCGE, the departure tax, and whether both countries tax the gain. Selling before departure and selling after produce sharply different results on both the Canadian and US sides.
Cross-BorderThe 183-day rule is a simplification that gets people into trouble. Canada uses residential ties. The US uses a weighted day count. You can be a tax resident of both countries at the same time, and the treaty tie-breaker is not automatic.
Cross-BorderIf you're a US person and your spouse owns 10% or more of a Canadian corporation, IRC 958(b) attributes those shares to you. The corporation becomes a CFC and Form 5471 follows, even though you don't hold a single share directly.
Cross-BorderITA 60(j) lets a Canadian resident deduct an RRSP contribution that matches a distribution from a US retirement account. The deduction offsets the income inclusion, making the transfer effectively tax-free in Canada, but the conditions, deadline, and the gap between gross and net are where most files go wrong.
Cross-BorderIf you left Canada and paid departure tax on the deemed disposition (ITA 128.1(4)), moving back to Canada may allow you to unwind that tax. ITA 128.1(6) allows an election to be deemed to have reacquired the property at the same cost as the departure, effectively reversing the departure tax, but only if specific conditions are met.
Cross-BorderThe child tax credit under IRC 24 can put $1,700+ per child in your pocket as a refundable credit if you use the FTC. If you use the FEIE (Form 2555), the exclusion reduces your tax to zero before the credit applies, and you get nothing.
Cross-BorderWhen a Canadian resident owns a US S-Corp or partnership, the flow-through income creates a mismatch. The US taxes the income as it is earned, while Canada may not recognize the entity the same way, producing timing differences, FTC basket issues, and a compliance load that catches most people off guard.
Cross-BorderUnder the treaty, US Social Security paid to a Canadian resident is taxable only in Canada. Canada includes 85% in income and allows a 15% deduction. The US does not withhold if the treaty claim is established.
Cross-BorderThe Social Security Fairness Act of 2025 eliminated the Windfall Elimination Provision and the Government Pension Offset. If you receive both CPP and US Social Security, your SS benefit likely went up, retroactive to January 2024.
Cross-BorderITA 128.1(8) lets you reduce the deemed gain at departure when you later sell at a loss. The catch is the property must still have been taxable Canadian property when you sold it, and most public stock portfolios do not qualify.
Cross-BorderIf you have earned benefits in both countries, the claiming order and age matter. CPP can start at 60 (with a reduction) or defer to 70 (with an increase). Social Security can start at 62 (reduced) or defer to 70 (increased). The WEP repeal changes the calculus.
Cross-BorderCanada does not recognize a 529 plan's tax-free status, so the CRA taxes the earnings annually once you become resident. The treaty does not cover it, and trust classification may add a US reporting layer.
Cross-BorderFIRPTA withholds 15% of the gross price at closing, often far more than the actual tax. How Form 8288-B reduces it, and how the 1040-NR gets the excess back.
Cross-BorderCanada does not recognize the ISO classification, so all stock options are taxed the same way on the Canadian side. Income splits between countries by the treaty's grant-to-exercise formula, and the 50% Canadian deduction creates an FTC mismatch.
Cross-BorderYou keep the HSA when you move to Canada, but you lose the triple tax advantage the day you arrive. Canada taxes HSA growth annually, you cannot contribute without a US HDHP, and the treaty does not cover it.
Cross-BorderThe One Big Beautiful Bill made TCJA individual rates permanent, raised the estate exemption to $15 million, and renamed GILTI. For cross-border filers, the changes to expensing, the new deductions for tips and overtime, and the estate threshold all shift the planning calculus.
Cross-BorderThe agreement prevents double FICA/CPP contributions when you work across the border. It assigns coverage to one country and lets you combine work credits to qualify for retirement benefits in both.
Cross-BorderNo state may tax the retirement income of someone who is neither its resident nor its domiciliary under 4 U.S.C. 114, and each state decides both under its own law.
Cross-BorderMoving to Canada does not move the ESPP discount out of the US tax net, because IRC 423(c) treats it as compensation sourced to where you worked. The same provision raises your cost basis by the discount amount, so the gain at sale adjusts accordingly.
Cross-BorderTwo of the three FHSA types at ITA 146.6(1) aren't trusts at all. Where yours is the trusteed kind, Rev. Proc. 2020-17 misses it on what it's for and not on the caps.
Cross-BorderCanada gives an individual 10 calendar years from that year's end under ITA 152(4.2), and the Minister may. The US runs 3 years from filing or 2 from payment under IRC 6511(a).
Cross-BorderThe domestic streamlined penalty is 5% of the highest year-end aggregate across the covered years, not your peak balance. Only unreported assets enter the base, so accounts you already disclosed are excluded from the calculation.
Cross-BorderYes, on Form RC4288. ITA 220(3.1) reaches penalty and interest but not the tax, ten years from year end. The CRA runs interest on a ten-year accrual clock. On GST/HST, ETA 281.1.
Cross-BorderYes. Form T1244 elects under ITA 220(4.5) to defer the tax on your deemed disposition, and the statute deems security accepted up to a floor amount.
Cross-BorderLeaving Canada does not eliminate your principal residence exemption. Form T2091 designates which years count. The exemption prorates by the ratio of designated years to total ownership years, and the plus-one rule is where most calculations go wrong.
Cross-BorderUsually not. Canadian Corporations and Companies are treated as corporations for US tax, so Form 8832 is closed to them. ULCs are the exception, and most need no election at all.
Cross-BorderForm 8840 claims the closer connection exception: fewer than 183 current-year days, a foreign tax home, and no green card. File it by June 15, because missing it forfeits the exception even though it does not change your actual residency status.
Cross-BorderYes if you're resident in Canada and a US corporation is your foreign affiliate: 1% yourself, 10% across related persons, 10 months after year end. Not in your first year here.
Cross-BorderNo. US self-employment tax generally reaches US citizens and residents wherever they live. Where it overlaps CPP, residence picks the one system, and a certificate proves it.
Cross-BorderNo, and the relief reaches back further than most write-ups say. But it left Form 8938 and the FBAR standing, and that carve-out is in the operative text.
Cross-BorderUnless exempt, the trust files it and the trustee signs, by the 15th day of the 3rd month after its year end. If it doesn't, the US owner attaches a signed substitute to Form 3520.
Cross-BorderGILTI still applies to 2025 tax years under its original rules, including the full QBAI deduction. The rename to net CFC tested income, the QBAI repeal, and the 40% deduction all take effect for tax years beginning after December 31, 2025.
Cross-BorderIf the move made you a US tax resident, the US taxes income from sources inside and outside the country. Source follows where you work rather than where the client is.
Cross-BorderThree layers hit at once: New York State residency, New York City tax, and nonresident sourcing. State and city each have two routes in, and the day-count route is the one people miss.
Cross-BorderA quiet disclosure files corrected returns without entering a formal IRS program, and it works when no penalties are at stake. If you later need Streamlined, penalties already assessed on the quiet-filed returns remain payable.
Cross-BorderFiling Form NR74 is usually unnecessary when you are moving to Canada and building residential ties. The CRA's own response says the opinion is not binding, and residency generally starts from the date of entry based on the facts.
Cross-BorderA gift or inheritance from a Canadian parent is not taxable income to the US recipient. If the total exceeds $100,000 in a year, Form 3520 is required, and missing it triggers a 5%-per-month penalty capped at 25%.
Cross-BorderForm 8833 is required when you take a treaty position that overrides a US tax rule and no waiver covers your situation. Whole categories of positions are waived at any amount, checked before the $10,000 floor, which applies to individuals.
Cross-BorderRenting a US property on Airbnb as a Canadian is taxed differently from a long-term lease. Short stays can end rental-activity status, and the passive-activity and self-employment rules interact in ways specific to nonresident aliens.
Cross-BorderITA 116(5) can assess a buyer 25% of the gross price when buying from a non-resident without a clearance certificate. For rented buildings or inventory the rate is 50%, and on inventory that rate is a floor, not a cap.
Cross-BorderBuying US property as a Canadian sets off four obligations, and they key to six different trigger dates. Here is the order they fire in, and which one to settle first.
Cross-BorderOrdinary section 1250 recapture on a post-1986 US residential rental is zero if you used straight-line depreciation. Up to 25% still hits the unrecaptured 1250 gain, and the Canadian side of the same sale carries its own reporting.
Cross-BorderCanadians can hold US real estate personally, through a trust, through an LLC, or through a corporation, and the estate tax outcome differs sharply. The right vehicle depends on the property's value, your estate plan, and whether the treaty credit covers the exposure.
Cross-BorderOn the Canadian side it mostly doesn't matter: arrival resets your cost to fair market value. US basis doesn't move, and T1135 can switch on unless the place is personal-use.
Cross-BorderBuying a Florida condo does not change your US day count, but it changes what those days mean under the closer-connection test. A condo available year-round becomes a second permanent home, and Form 8840 line 15 asks you to explain it.
Cross-BorderThe $60,000 US estate tax exemption for non-citizens is not the end of the analysis. The treaty can trade that amount for a pro-rata share of the full $15 million exclusion, but the IRS requires a filed Form 706-NA to claim it.
Cross-BorderThree problems, two sides of the border: US corporate tax, a Canadian shareholder benefit, and the cost of getting out. CRA treats the property as a benefit if the place is available for personal use, and the filing burden adds up fast.
Cross-BorderThe US withholds 30% of gross rent from a nonresident's US property by default, with no deductions allowed. The Section 871(d) election switches to graduated rates on net income after expenses, and the first election can usually be filed late.
Cross-BorderDaily commuting from Canada usually keeps you off the US substantial presence test, because days you return home within 24 hours are excluded. The 75% rule and the working-period definition are where most commuters get the math wrong.
Cross-BorderCanada taxes your remote pay first, because you're resident here. What you owe, what your US employer owes Canada, and the forms both sides need.
Cross-BorderA US person who owns 10% or more of a Canadian corporation, or controls it, must file Form 5471. A missed year costs $10,000, and the return can stay open to IRS assessment until you file.
Cross-BorderDual-status is the default in your arrival year. Three separate elections can change that, and two of them generally need a spouse. Here's which is which.
Cross-BorderA section 6677 penalty on a TFSA is assessable, so it can land before anyone reads your explanation. The routes back are abatement, Appeals or a refund claim, each with a clock.
Cross-BorderA paid assessment is worth it when your file holds an unknown that changes the price or the plan. If you already know which returns you need, skip it.
Cross-BorderAn LLC formed while you're still a Canadian resident usually lands in a mismatch Canada doesn't fix, and an S corporation is closed to a nonresident alien.
Cross-BorderCalifornia does not follow the US-Canada treaty provision that defers tax on RRSP growth. A California resident reports RRSP earnings yearly, even when nothing is withdrawn, making the state return more expensive than the federal one.
Cross-BorderFlorida levies no personal income tax, but the cost of the move lands on the Canadian side, on the way out. Here is the sequence, and the dates that decide it.
Cross-BorderRenouncing US citizenship triggers Form 8854 and a five-year compliance certification on every US return. Fail the certification and you are a covered expatriate at any net worth, so the catch-up comes before the renunciation.
Cross-BorderA section 217 election trades the flat 25% withholding on non-resident RRSP income for graduated Canadian rates. Who wins, the June 30 wall, and the math.
Cross-BorderUS brokerage and bank accounts count toward the T1135's $100,000 cost-amount line while you're a Canadian resident. The penalties, and the two late routes: file late with a relief request, or apply to the CRA's Voluntary Disclosures Program.
Cross-BorderUnreported employment income usually pushes you into Streamlined rather than the simpler delinquent FBAR route. The delinquent path excluded anyone who needed to amend a return, and the IRS removed it entirely in mid-2026.
Cross-BorderYour LIRA is not deemed sold when you leave Canada, and it keeps growing tax-deferred. Whether you can unlock it as a non-resident, and how long you wait, depends on the pension legislation governing the account.
Cross-BorderThere's no flat 182-day safe number. The substantial presence test weights three years, so 122 days each winter, three winters running, already meets it.
Cross-BorderCanadian residence restarts when you establish ties, and the Act deems what you own sold and reacquired at fair market value. This checklist covers the deemed acquisition, your cost base reset, and what to file in year one.
Cross-BorderUsually yes for a 401(k), though CRA has never confirmed it: ITA 60(j) gives a deduction if five conditions hold and you fund the RRSP in time. A Roth generally can't.
Cross-BorderReceiving a W-2 and a T4 on the same RSU tranche does not mean you are being double-taxed. Each country runs its own inclusion rule and taxes its share of the vesting period. The two amounts need not add up to the full tranche.
Cross-BorderA Roth IRA in Canada stays tax-free in most cases, on three separate tracks under the treaty. The XVIII(7) election defers the annual tax, contributing nothing keeps pension status, and XVIII(1) exempts a US-untaxed payout.
Cross-BorderNo CRA description of Form NR73 we could locate makes it mandatory, and what it gives back is an opinion that doesn't bind the CRA. Two fact patterns still make it worth filing.
Cross-BorderA spouse who stays in Canada is usually a significant residential tie, which can push your Canadian departure date past your own flight. The US side runs separately.
Cross-BorderYour residential ties decide the first test, and CRA runs the tests in a defined order. The treaty tie-breaker only starts if the US also claims you as its resident.
Cross-BorderFor a Canadian resident who isn't a US citizen or green-card holder, 15% applies only where the payment is periodic; a pre-tax lump sum stays at 30%. A US person files a W-9.
Cross-BorderIf you are a US resident and no longer Canadian, CPP and OAS are taxable only in the US under the treaty. Canada's withholding drops to nil, the OAS clawback does not reach you, and the payments go on the Social Security worksheet.
Cross-BorderBoth tax it. Canada's gain runs from an acquisition date a complete rental conversion moves unless you elect out. The US reaches a non-citizen's post-move rise, if s. 121 doesn't.
Cross-BorderWinding up a Canadian corporation before emigrating is usually the better move, because the CDA comes out tax-free only while you are resident. Once US residency starts, the liquidation becomes a taxable event on both sides of the border.
Cross-BorderKept your Canadian rental after moving to the US? Canada withholds 25% of the gross rent. An approved NR6 drops withholding to net income, and a section 216 return gets the rest back.
Cross-BorderLate FBARs go through FinCEN with a reasonable-cause explanation. No penalty where income was already reported. What the IRS accepts, how to write the explanation, and the penalties if you don't.
Cross-BorderYour corporation stays Canadian, but it stops being a CCPC the day control passes to a non-resident. It becomes a controlled foreign corporation on your US return, triggering Form 5471 and potentially GILTI.
Cross-BorderCanada calls your US LLC a corporation and the IRS calls it nothing, so the same profit gets taxed twice. Here's the math, and the fix options side by side.
Cross-BorderYes, almost always. Canadian mutual funds and ETFs are PFICs; GICs and cash aren't. Form 8621 runs one per fund, from $400 a year, unless an exception applies.
Cross-BorderCanada's departure tax does not automatically raise your US cost basis to match the deemed proceeds. You need the Article XIII(7) treaty election on your US return for the move year, or the two countries tax the same gain twice.
Cross-BorderUS citizens living in Canada must file US tax returns regardless of where they earn their income. A catch-up program clears five penalty categories for eligible filers: three years of returns, six years of FBARs, and one certification form.
Cross-BorderYou can keep the RESP, but contributions and the CESG stop when your child leaves Canada. The CCB ends too, and the IRS side turns on Rev. Proc. 2020-17.
Cross-BorderYes, your TN days count toward the substantial presence test. Arrive by mid-year and you'll likely file a dual-status return. Here's the day math and the forms.
Cross-BorderMost E-2 movers become US tax residents the year they land and file a final Canadian return with a departure date. Add FBAR plus Form 5471 if you keep the Canadian corporation, and the filing stack is longer than most first-year movers expect.
Cross-BorderOnly if you're both a long-term resident (green card in 8 of the last 15 taxable years) and a covered expatriate. Plenty of people are neither. Timing decides it.
Cross-BorderThe full leaving-Canada tax checklist, covering every step from severing ties to filing your final return. Departure tax, T1161, RRSP, TFSA, CPP, OAS, and the forms CRA uses to track you.
Cross-BorderNeither account is deemed sold when you leave Canada, but the US treatment diverges sharply. The RRSP keeps its tax deferral automatically. The TFSA loses its tax-free status on day one and becomes a regular taxable account for US purposes.
Cross-BorderWithout a section 116 clearance certificate (also called a certificate of compliance), the buyer holds back 25% of your full sale price. On a rented-out building it's 50%, less any T2062A certificate amount.
Cross-BorderUsually yes. Canada's departure tax (also called the exit tax) triggers a deemed sale of most property at fair market value when you leave. Here are the forms (T1161, T1243), the penalties, and the worked math.
Cross-BorderThe IRS has never ruled definitively on whether a TFSA is a foreign trust for Form 3520 and 3520-A purposes. Two defensible positions exist, and a 2024 proposed rule may exempt accounts under a $50,000 aggregate cap.
Cross-BorderRRIF withdrawals inside the yearly ceiling get the 15% treaty rate; an RRSP lump sum is withheld at 25%. Here are the rules, the ceiling, and the ten-year math.
Cross-BorderMost Canadian streamlined files cost US$2,500 to $4,500 in preparer fees, and a typical employee file owes $0 US tax. Accounts drive the spread: more accounts means more FBARs, more Form 8938 schedules, and more PFIC reporting if you hold Canadian mutual funds.
Cross-BorderA $1,200 TFSA quote usually means protective Form 3520 and 3520-A filings for every account. Here's what that work involves and when the number is fair.
Cross-BorderCanada's departure tax, also called the exit tax, deems most of your property sold at fair market value when you cease residence. Five statutory exclusions cut into that.