Who We Serve · U.S.–Canada
U.S. and Canadian tax rules often apply to the same person at the same time, and U.S. filings are easy to get wrong. Through LCW Tax Advisory (Canada) Limited, we help Americans in Canada and Canadians with U.S. ties meet their U.S. tax obligations.
Who This Is For
You file in Canada, but the U.S. still requires a return each year. We prepare U.S. returns that work with your Canadian filings, align foreign tax credits, report TFSAs and RESPs correctly, and document treaty positions.
A move south, a U.S. rental property, or a stake in a U.S. business each carry U.S. tax filings. We advise before you cross the border on residency start dates, departure planning, and elections that must be made on time.
Moving north does not end your U.S. filing requirements. We plan the transition year, help keep both systems from taxing the same income twice, and flag Canadian accounts that carry U.S. reporting consequences.
Dual citizens, cross-border marriages, children born in either country, and inheritances that cross the border all raise questions. We help work out who must file what, in which country, and how the two returns fit together.
Scope
Every engagement is scoped in writing before work begins. These are the matters that most often bring U.S.–Canada clients to us.
Discuss your situationInsights
From Florida condos to Arizona rentals, Canadian owners of US property face a defined set of US filings — the 1040-NR, the net-rental election, ITINs, and FIRPTA withholding at sale. A walkthrough of the lifecycle.
Read articleCanada's favourite tax-sheltered accounts lose their shelter at the border. How the IRS treats TFSAs, RESPs, FHSAs and RRSPs in the hands of US persons — and what to do about it.
Read articleA plain-language overview of the US filing obligations that follow American citizens and green card holders to Canada — the annual return, the FBAR, and the traps hiding inside ordinary Canadian accounts.
Read articleFAQ
Yes. U.S. citizens and green card holders must generally file a U.S. return on worldwide income wherever they live. Because Canadian tax rates are usually higher, foreign tax credits often reduce the U.S. tax to zero. The return, the FBAR and related disclosures are still required, and some Canadian accounts can create U.S. tax even when none is expected.
The U.S. does not recognize the tax-free status of a TFSA, so its income is generally taxable on your U.S. return, and the account itself is reportable. Depending on its holdings, PFIC reporting may apply to the funds inside it. Many Americans in Canada reconsider how they hold these savings once they understand the U.S. treatment.
A non-resident with U.S. rental income generally files Form 1040-NR each year, and most owners elect to be taxed on a net basis rather than face 30% withholding on gross rents. When you sell, FIRPTA withholding applies at closing unless it is reduced by certificate. An ITIN is usually the first step, and we handle each of these filings.
Before you move, ideally several months ahead. Residency start dates, the timing of gains, RRSP and TFSA decisions, and entity elections are far more useful as planning than as after-the-fact repair. A pre-move consultation often saves more than it costs.
Our practice is the U.S. side of the border. We regularly coordinate with Canadian accountants, whether yours or ones we work with, so the two returns are prepared consistently rather than in isolation.
Work with us
Tell us which direction you are moving and what you own. We will outline the U.S. filings, note any planning deadlines, and quote a defined scope.
International US Tax
A specialist international U.S. tax firm providing trusted tax advisory, planning, and compliance services for individuals, businesses, and trusts.