Who We Serve · U.S.–Canada
U.S.–Canada cross-border tax
Living in Canada doesn’t end your U.S. tax obligations. We help U.S. citizens, green card holders, and Canadians with U.S. connections manage their U.S. tax reporting, planning, and compliance.
Who This Is For
People we work with
U.S. citizens and green card holders in Canada
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.
Canadians moving to or investing in the U.S.
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.
U.S. persons moving to Canada
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.
Cross-border families and dual citizens
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
What we handle on the U.S. side
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 situation- U.S. individual returns (Form 1040 and 1040-NR) coordinated with Canadian filings
- Streamlined Filing Compliance Procedures for Americans in Canada who are behind on filings
- FBAR and Form 8938 reporting of Canadian accounts, RRSPs, TFSAs and RESPs
- U.S. treatment of TFSAs, RESPs, FHSAs and other registered accounts
- Canadian corporations owned by U.S. persons, including Form 5471, GILTI and section 962 analysis
- Canadians with U.S. LLCs, C corporations and partnerships, including Forms 5472, 1120 and 1065
- U.S.–Canada treaty positions, including Form 8833 disclosures
- Snowbirds and the substantial presence test, including Form 8840 closer connection claims
Insights
U.S.–Canada Tax Insights
RRSP and RRIF Withdrawals: The US-Taxable Amount and Your Foreign Tax Credit
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The 70% Tax Trap: How PFICs Create Double Taxation for Americans in Canada
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Canadians Owning US Real Estate: Rental Income, FIRPTA and the Exit
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TFSAs, RESPs and FHSAs: How the US Taxes Canadian Registered Accounts
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US Citizens Living in Canada: What You Still Owe the IRS
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Canadians Moving to the US: The Pre-Move Tax Checklist
Read article FAQ
U.S.–Canada — common questions
I am an American living in Canada and I pay a lot of Canadian tax. Do I still need to file in the U.S.?
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.
Is my TFSA taxable in the U.S.?
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.
I am Canadian and bought a U.S. rental property. What filings do I have?
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.
We are moving from Toronto to the U.S. next year. When should we talk?
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.
Do you also prepare Canadian returns?
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
Have U.S.–Canada tax questions?
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.