Canadians owning, renting, and selling US property and Americans owning Canadian property: FIRPTA, the section 116 certificate, rental elections, Airbnb income, how to hold title, and the principal residence rules.
24 guides, each written by a CPA licensed in the US and Canada.
How Airbnb and Vrbo withhold US tax from non-resident property owners, the difference between W-8BEN and W-8ECI. Covers key rules, filing requirements,.
Cross-BorderHow you hold a US vacation rental affects cost segregation, platform withholding, passive activity grouping, estate tax, and Canadian reporting.
Cross-BorderBuy a US property as a Canadian and four obligations attach: a US charge on rental income, withholding on the sale keyed to gross price.
Cross-BorderWhen a Canadian sells US real estate, the buyer withholds 15% under FIRPTA, the IRS taxes the gain, and Canada taxes it too (with an FTC).
Cross-BorderDividing property in a cross-border divorce can trigger tax in both Canada and the US. Treaty rules and each country's rollover provisions matter.
Cross-BorderElect net-basis tax or lose 30% (US) or 25% (Canada) of gross rent to withholding: IRC 871(d) and Form W-8ECI in the US.
Cross-BorderOwning rental property across the border creates filing obligations in both countries. Withholding, treaty elections, and foreign tax credits apply.
Cross-BorderOwning rental property across the Canada-US border creates filing obligations in both countries. Each country taxes the income and requires specific forms.
Cross-BorderCost segregation on a vacation rental triggers IRC 1245 ordinary recapture on sale, and FIRPTA withholding at closing may not cover the actual tax bill.
Cross-BorderSelling US property from Canada? The buyer usually withholds 15% of the gross price. Cut it with Form 8288-B, recover it on a 1040-NR, and credit the US tax in Canada.
Cross-BorderThe two regimes look alike from a distance and behave very differently up close, and the difference is where the money is lost.
Cross-BorderShort-term US rentals by Canadian owners trigger different passive activity and withholding rules than long-term leases.
Cross-BorderSection 1250(a) recapture is zero on a post-1986 straight-line residential rental held more than a year (sell inside a year and it's real).
Cross-BorderWithout a section 116 certificate, the buyer holds back 25% of the full sale price. File T2062 before closing. On a rented building the holdback is 50%.
Cross-BorderYes. ITA 116(5) makes you liable for 25% of the full price if the non-resident seller lacks a clearance certificate. Covers treaty provisions, foreign tax.
Cross-BorderIt depends on the property's value, estate plan, and exposure. It depends on the axis, and this page lays out each rather than picking for you.
Cross-BorderRent from a US property pays a flat 30% of the gross to the IRS, with no deductions allowed against it, and that is the default for a Canadian who hasn't.
Cross-BorderHow Canadian EI maternity and parental benefits and employer top-ups are taxed when a family has US filing obligations, including the treaty rule and the US return.
Cross-BorderIn the US, mortgage interest on your principal residence and one additional home is deductible if you itemize (up to $750,000 of acquisition debt).
Cross-BorderListing a US LLC on Airbnb changes the trade-or-business classification, withholding, and FAPI on the Canadian side. Compare LLC, S-Corp, and sole.
Cross-BorderIt might be, and the fix has a price either way. Three problems run at once, on two sides of the border. Three problems run at once.
Cross-BorderHow the Canadian principal residence exemption under ITA 40(2)(b) and the US section 121 exclusion interact when you sell a home after crossing the border.
Cross-BorderHow royalties are taxed when a Canadian licenses IP to a US company or the reverse: treaty rates of 0% or 10% under Article XII, the withholding forms, and foreign tax credits.
Cross-BorderHow the Canadian principal residence exemption and the US Section 121 exclusion interact when you sell a home after moving across the border.