US-Canada Cross-Border Tax Services
Discuss your US and Canadian filing needs, account reporting and prior returns. Confirm the preparation scope and fees before starting an engagement.
Cross-Border Tax Clients We Serve
Whether you live in Canada, work in the United States or split time between both countries, bring your residence dates, income records and prior returns to the consultation.
US Citizens Living in Canada
Living in Canada does not by itself remove US filing obligations. Your worldwide income, filing status, age and other filing triggers determine whether a US return is required. Review Canadian filing requirements separately and bring your prior returns and account records.
Canadians Working in the US
Bring your immigration status, residence history, move dates and income records. Discuss which US and Canadian filings need review and confirm the services included in your engagement.
US-Canada Dual Citizens
Bring your citizenship and residence history, income records and financial account details. Identify the returns and information reports needed in each country before agreeing to the preparation scope.
Canadian Snowbirds (Part-Year US Residents)
For snowbirds who are not US citizens or green card holders, count US days across three years, not just this year. The substantial presence test requires at least 31 days this year and a weighted total of 183 days. Day-count exclusions and residency exceptions need separate review.
What Makes US-Canada Cross-Border Tax Complex
Review income tax returns, account reports and treaty provisions separately so the preparation scope reflects your circumstances.
Dual Filing Obligations
Determine filing requirements separately in each country. US citizens and residents abroad generally follow the same filing rules as those in the United States. CRA lists circumstances requiring a Canadian return and reasons to file for refunds, benefits and credits. A filing obligation does not by itself establish the tax owed.
The US-Canada Tax Treaty
The treaty addresses different income categories and relief from double taxation. Its saving clause generally preserves US taxation of citizens and residents, subject to exceptions. Identify the relevant article and eligibility before claiming a benefit.
RRSP, TFSA, and RESP Reporting on the US Return
Review RRSP deferral eligibility under Revenue Procedure 2014-55. For TFSA and RESP accounts, examine the account agreement, holdings and your role before determining US reporting. Foreign-trust reporting exceptions and PFIC filing rules have their own conditions; an account name alone does not settle every obligation.
FBAR and FATCA for Canadian Accounts
A US person generally must file an FBAR when foreign financial accounts in which they have a financial interest or signature authority exceed US$10,000 in aggregate at any time during the year; exceptions apply. Form 8938 is separate: thresholds depend on filing status and qualifying residence abroad, and specified assets and exceptions must be reviewed.
Principal Residence Gains
Canadian principal residence relief depends on qualification, designation and reporting; it does not exempt every home sale in full. The US exclusion has separate ownership and use tests, limits and exceptions. Review residence history, purchase records, improvements and any rental use before calculating either country’s treatment.
Social Security Totalization Agreement
US-Canada social security coordination and the separate Quebec understanding have their own coverage rules. SSA assigns self-employed residents of Canada to Canadian or Quebec coverage. A certificate establishes an exemption from US Social Security contributions; coverage should be reviewed separately from income tax.
Currency Conversion Complexities
US returns generally report amounts in US dollars. Apply the exchange-rate method appropriate to the item and keep the underlying records. Do not assume one annual average rate is suitable for every transaction or information return.
State Tax Obligations from Your Former US State
State tax needs a separate review of residency, move dates and income sources. California, for example, may tax a nonresident’s California-source income, and residents are taxed on worldwide income. Bring employment, business and property records rather than assuming a move ends every state filing requirement.
Our US-Canada Cross-Border Tax Services
Use these topics to discuss your preparation needs. Confirm which services and filings are included in the written engagement.
US Form 1040 + Canadian T1 Preparation
Before starting, confirm which US and Canadian returns are included in your engagement and how information will be coordinated. Foreign tax credits are subject to eligibility and limitations; do not assume every payment in one country offsets tax in the other.
Foreign Earned Income Exclusion vs. Foreign Tax Credit Optimization
Compare the foreign tax credit and foreign earned income exclusion using your income, qualifying foreign taxes and eligibility. The exclusion requires foreign earned income, a foreign tax home and a qualifying residence or presence test. Taxes on excluded income cannot also generate a foreign tax credit.
RRSP Deferral Eligibility
Eligible individuals are treated as having elected deferral of undistributed Canadian retirement-plan income under Revenue Procedure 2014-55. Check eligibility and prior reporting before applying this treatment; an annual RRSP election statement is not generally required for eligible individuals.
TFSA Remediation and PFIC Cleanup
Bring TFSA agreements, investment statements and prior returns for review. Determine whether PFIC or foreign-trust reporting applies, including available exceptions, before deciding whether amended filings or investment changes are appropriate. This page does not recommend closing an account.
FBAR and FATCA Filing for Canadian Accounts
List foreign accounts, ownership, signature authority and values for a separate FBAR and Form 8938 review. These reports have different definitions, thresholds and exceptions. Confirm which filings are included in the quote rather than assuming every account requires both reports.
Cross-Border Relocation Planning
Before relocating, list your assets, residence history and planned transactions for review. Canadian departure rules apply to certain property, with exceptions. US expatriation rules require a separate review; moving across the border alone does not establish the tax outcome.
Streamlined Filing for Delinquent Filers
Start with an eligibility review before choosing a catch-up procedure. IRS Streamlined Foreign Offshore relief requires non-willful conduct, the applicable non-residency test and all other eligibility and submission requirements. Required tax and interest remain payable. Canadian disclosure options require a separate assessment.
Canadian Departure Tax and US Exit Tax Planning
Canada’s departure rules can treat certain property as sold at fair market value when residence ends; exceptions include Canadian real property and specified registered plans. US expatriation tax has different rules, including covered-expatriate criteria. Review eligibility, reporting and available elections before ending residence or relinquishing status.
Cross-Border Business Structuring
Canadian corporate ownership may trigger US reporting, but ownership alone does not settle CFC status or every Form 5471 requirement. Review ownership percentages, attribution rules, transactions and the applicable filer categories before deciding which forms and income inclusions apply.
Estate Planning for Cross-Border Families
Before making estate-planning decisions, gather asset ownership records, residence and citizenship details, wills and beneficiary designations. Ask which tax and legal professionals need to be involved and confirm their responsibilities.
Define Your Cross-Border Filing Quote
Request a written quote based on the required forms, tax years and account details. Confirm fees and support terms before starting.
Individual Filing
Confirm the returns and reports included
- US and Canadian preparation responsibilities
- Required account reports and information returns
- Tax years covered
- Fee currency, payment terms and exclusions
Accounts, Investments or Business Income
Identify additional reporting before agreeing to scope
- Retirement and savings account details
- Fund holdings and transaction records
- Self-employment and rental records
- Additional forms and their fees
Catch-Up or Relocation
Discuss prior filings and planned changes
- Years of missing or amended filings
- Tax-authority correspondence
- Move dates and residence history
- Separate tax and legal review needs
US-Canada Treaty Topics to Review
Discuss which treaty provisions may apply to your income and circumstances, including their conditions and reporting requirements.
Read our US-Canada tax filing guide for background on retirement accounts and reporting requirements before your consultation.
Residence Tiebreaker
Dual-resident taxpayers may need the treaty’s residence rules. Treaty residence does not automatically remove US tax obligations because the saving clause and its exceptions must also be considered. Review the facts before claiming treaty treatment.
RRSP and RRIF Deferral
Revenue Procedure 2014-55 provides automatic deferral for eligible individuals with qualifying Canadian retirement plans. Eligibility includes prior return filing and income-reporting conditions. Distributions and separate account reporting still need review.
Capital Gains Provisions
Treaty treatment of gains depends on the property and circumstances. Canadian real property is not covered by the general exemption described for certain personal-property gains of US residents. Review the relevant provision before a sale.
Elimination of Double Taxation
Double-tax relief is subject to treaty provisions and domestic credit rules. Special foreign tax credit rules may apply to US citizens residing in Canada. Review income sources and credit limitations rather than assuming a full offset.
CPP vs. FICA
Social security coverage is separate from income tax treaty relief. Where Canadian or Quebec coverage applies, SSA describes certificates CPT56 and QUE/USA 101 to establish an exemption from US contributions. Bring coverage documents to the consultation.
How Our Cross-Border Process Works
Confirm the agreed scope, responsibilities and filing methods before preparation begins.
Free Consultation
Discuss your filing history, accounts and preparation needs. The initial call helps establish next steps and scope; it is not a completed tax analysis.
Gather Documents
Gather prior returns, income slips, account statements and relevant correspondence. Confirm the required documents and how to provide them securely before sending sensitive information.
Coordinated Preparation
Agree which returns and information reports will be prepared, who handles each country’s filing, and how the necessary information will be coordinated.
Review and Confirm Filing
Review the prepared documents before authorizing submission. Confirm each filing method, deadline and completion record, and retain copies for your records.
US-Canada Cross-Border Tax FAQs
Answers to the most common questions from Americans in Canada, Canadians in the US, and dual citizens navigating both tax systems.
Do I need to file taxes in both the US and Canada?
Can I claim Canadian taxes paid on my US return?
How is my RRSP taxed in the US?
Is my TFSA taxable in the US?
Do Canadian snowbirds need to file US taxes?
What happens if I haven't filed in either country?
How much does cross-border tax filing cost?
Why should I use a specialist instead of a regular accountant?
Source references checked September 23, 2026.
Sources for reviewed topics — read September 23, 2026
- IRS Revenue Procedure 2014-55
- Substantial presence test
- Closer connection exception to the substantial presence test
- Us taxpayers residing outside the united states
- CRA Voluntary Disclosures Program
- Foreign tax credit
- Foreign earned income exclusion
- IRS Form 3520 instructions
- IRS Form 8621 instructions
- Foreign currency and currency exchange rates
- CRA departure-property rules
- Expatriation tax
- IRS Form 5471 instructions
- Us citizens and residents abroad filing requirements
- CRA filing requirements
- Report of foreign bank and financial accounts fbar
- IRS Form 8938 instructions
- CRA principal residence rules
- IRS home-sale exclusion
- California residency and filing requirements
- SSA agreement with Canada
- IRS US-Canada treaty guidance
Discuss Your Cross-Border Filing Needs
Bring your filing history and account details to discuss preparation scope and next steps.
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