Who We Serve · US–Canada

Two tax systems. One coherent plan.

The US–Canada border is the busiest cross-border tax corridor in the world — and one of the easiest places to get US filings wrong. Through LCW Tax Advisory (Canada) Limited, we serve Americans in Canada and Canadians with US ties as a core practice, not a sideline.

Who This Is For

Situations we work with every week

US citizens & green card holders in Canada

You file in Canada — but the US still expects a return every year. We prepare US returns that work with your Canadian filings: foreign tax credits aligned, TFSAs and RESPs reported correctly, and treaty positions documented.

Canadians moving to or investing in the US

A move south, a US rental property, a stake in a US business. We advise before the border is crossed — residency start dates, departure planning, and the elections that are only available if made on time.

US persons moving to Canada

Heading north does not end your US filing life; it makes it more interesting. We plan the transition year, keep both systems from taxing the same dollar twice, and flag Canadian accounts that carry US reporting consequences.

Cross-border families & dual citizens

Dual citizens, cross-border marriages, children born in either country, inheritances that cross the line. We untangle who must file what, in which country, and how the two returns should fit together.

Scope

What we handle on the US side

Every engagement is scoped in writing before work begins. These are the matters that most often bring US–Canada clients to us.

Discuss your situation
  • US individual returns (Form 1040 / 1040-NR) coordinated with Canadian filings
  • Streamlined Filing Compliance Procedures for Americans in Canada who are behind
  • FBAR & Form 8938 reporting of Canadian accounts, RRSPs, TFSAs and RESPs
  • US treatment of TFSAs, RESPs, FHSAs and other registered accounts
  • Canadian corporations owned by US persons — Form 5471, GILTI and section 962 analysis
  • Canadians with US LLCs, C corps and partnerships — Forms 5472, 1120, 1065
  • US–Canada treaty positions, including Form 8833 disclosures
  • Snowbirds and the substantial presence test — Form 8840 closer connection claims

FAQ

US–Canada — common questions

I am an American living in Canada and I pay lots of Canadian tax. Do I still need to file in the US?

Yes. US citizens and green card holders must generally file a US return on worldwide income wherever they live. Because Canadian tax rates are usually higher, foreign tax credits often reduce the US tax to zero — but the return, the FBAR and related disclosures are still required, and some Canadian accounts can create US tax even when none is expected.

Is my TFSA really taxable in the US?

The US does not recognise the TFSA’s tax-free status, so its income is generally taxable on your US return, and the account itself is reportable. Depending on its contents, PFIC reporting may apply to the funds inside it. Many Americans in Canada restructure their savings once they see the full picture.

I am Canadian and bought a US rental property. What filings do I have?

A non-resident with US rental income generally files Form 1040-NR each year, and most owners elect to be taxed on a net basis rather than suffer 30% withholding on gross rents. When you sell, FIRPTA withholding applies at closing unless reduced by certificate. An ITIN is usually the first step — we handle all of it.

We are moving from Toronto to the US next year. When should we talk?

Before you move — ideally several months before. Residency start dates, the timing of gains, RRSP and TFSA decisions, and entity elections are far more valuable as planning than as repair. A single pre-move consultation often pays for itself many times over.

Do you also prepare Canadian returns?

Our practice is the US side of the border. We routinely coordinate with Canadian accountants — yours or ones we work with regularly — so the two returns are prepared consistently rather than in isolation.

Work with us

On either side of the 49th parallel?

Tell us which way you are crossing and what you own. We will map the US filings, flag the planning windows, and quote a defined scope.