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Guides

Straight answers, written by the people who’d file it.

1,423 plain-English guides on cross-border moves, US and Canadian returns, and small-business money. Each one ends in what to do next, and says when a written Position Check is the smarter first step.

CROSS-BORDER A Canadian Corporation With a U.S. Shareholder
  • What applies to you
  • What it costs if you wait
  • What to do next
1,423 guides
Cross-Border Tax (U.S.–Canada)

CRA T1135 Penalties: What a Missed Foreign Property Report Costs, and the Three Ways to Fix It

September 13, 2026

Form T1135 reports foreign property costing more than $100,000. The late-filing penalty is $25 a day to $2,500, rising to $500 a month for knowing failures and $1,000 a month after a demand, plus a reassessment period extended by three years. Here is the penalty structure, what triggers each tier, and the Voluntary Disclosures Program, taxpayer relief, and simple late filing as the fixes.

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Cross-Border Tax (U.S.–Canada)

CRA Voluntary Disclosures for Cross-Border Filers: Coordinating With an IRS Streamlined Submission So Neither Agency Hears It First From the Other

September 13, 2026

A taxpayer catching up in both countries files a CRA Voluntary Disclosure and an IRS streamlined submission as one project. Each program requires that the agency has not already contacted the taxpayer, and the two agencies share information. Here is the CRA program's conditions and relief, the sequencing, and what the two disclosures must agree on.

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Cross-Border Tax (U.S.–Canada)

Owing Penalties in Both Countries: How the CRA's and IRS's Penalties Stack, What Each Program Waives, and the Order to Approach Them

September 13, 2026

Penalties are not creditable across the border: a Canadian late-filing penalty does not reduce a US one, and neither country's disclosure program touches the other's penalties. Here is how the two penalty systems stack on a typical cross-border omission, what the VDP and streamlined each waive, and how to sequence the two so both waivers are available.

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Cross-Border Tax (U.S.–Canada)

How Cryptocurrency Complicates a Streamlined Filing Catch-Up: Every Disposition, Missing Basis, and the Foreign-Exchange Question

September 13, 2026

Crypto in a streamlined submission means reconstructing every disposition for the covered years as a taxable event, establishing basis from exchange records, deciding whether exchange holdings are reportable on Form 8938 (and, so far, not on the FBAR), and including staking and airdrop income. Here is the mechanics and the judgment calls.

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Cross-Border Tax (U.S.–Canada)

My Parent Died Owing the CRA or the IRS: Does the Estate Pay, and Can the Debt Reach the Kids?

September 13, 2026

A parent dies with tax owing in one or both countries. The estate pays before the heirs inherit; the children are not personally liable for the shortfall — but the executor can be, and both countries have transferee rules that follow property given away. Here is who owes what, in what order, and the certificates that protect the executor.

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Cross-Border Tax (U.S.–Canada)

Deemed Disposition at Death vs the US Stepped-Up Basis: Two Systems, One Estate, and Where They Collide

September 13, 2026

Canada taxes the gain at death; the US forgives it and taxes the estate's value instead. For a cross-border family the two systems overlap on the same assets: a deemed disposition on the final T1, a possible US estate tax, and a basis answer that differs by country. Here is how each system works, how the treaty credits them against each other, and the basis traps for the heirs.

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Cross-Border Tax (U.S.–Canada)

Estate Freezes, Alter Ego Trusts, and Bypass Trusts: Three Classic Structures and How Each Breaks When the Family Crosses the Border

September 13, 2026

Each country's estate planning toolkit is built for its own tax system — and exports badly. A Canadian estate freeze puts growth shares into a trust that may have US beneficiaries; an alter ego trust avoids probate but reads oddly to the IRS; a US-style bypass trust solves a problem Canada does not have. Here is what each structure does at home and where it fails abroad.

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Cross-Border Tax (U.S.–Canada)

Executor of a Cross-Border Estate: Where Your Personal Liability Comes From and the Certificates That End It

September 13, 2026

An executor who distributes before the tax is settled can be personally liable in both countries — Canada through the clearance certificate rules, the US through the federal claims priority and the fiduciary rules. Here is the liability map for an executor handling an estate with U.S. and Canadian filings, and the sequence of certificates and discharge requests that closes it.

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Cross-Border Tax (U.S.–Canada)

Form 3520 Penalty Abatement: The IRS's October 2024 Policy Change and What It Means for a Late Foreign Gift or TFSA Report

September 13, 2026

The IRS used to assess Form 3520 penalties automatically on late filings, up to 25% of a foreign gift or 35% of a foreign trust transaction, and taxpayers fought them afterward. In October 2024 the IRS announced it would review reasonable-cause statements before assessing the gift and bequest penalty. Here is what changed, what did not, and how to file a late Form 3520 now.

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Cross-Border Tax (U.S.–Canada)

Form 5471 and 5472 Penalties: The Abatement Paths After Farhy and Mukhi, and Why the IRS Still Assesses

September 13, 2026

The Tax Court held in Farhy that the IRS cannot assess Form 5471 penalties under section 6038(b) without a court judgment; the D.C. Circuit reversed; the Tax Court reaffirmed in Mukhi for taxpayers outside that circuit. The IRS continues to assess. Here is the state of the law, the paths to abatement (reasonable cause, first-time abatement, the Farhy argument, DIIRSP, streamlined), and what a Canadian corporation's owner should do with a notice.

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Cross-Border Tax (U.S.–Canada)

Form 706-NA in Detail: When a Canadian Estate Owes the US a Return, What Counts as US-Situs, and How the Treaty Credit Works

September 13, 2026

A Canadian who dies owning more than $60,000 of US-situated assets leaves an estate with a US filing obligation — even if the treaty wipes out the tax. Here is what Form 706-NA covers: the situs rules, the $60,000 threshold, the pro-rated treaty credit, the marital credit, and the transfer certificate that holds the assets hostage until the IRS signs off.

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Cross-Border Tax (U.S.–Canada)

I Have a Green Card and Live in Canada. Can I Use Streamlined to Catch Up? Yes, and the Submission Should Not Claim the Treaty

September 13, 2026

A green card holder living in Canada who has not filed US returns can use the foreign streamlined track (the residency test is met on days abroad). The returns should be filed as a US resident with the foreign tax credit, not as a treaty non-resident, because a treaty claim on a streamlined return risks the green card and, for a long-term resident, triggers the expatriation rules. Here is the submission and the decision that follows.

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Cross-Border Tax (U.S.–Canada)

In-Trust-For (ITF) Accounts: The Informal Trust That Causes Formal Problems When the Family Is Cross-Border

September 13, 2026

An ITF account — money invested 'in trust for' a child with no trust deed — is easy to open and hard to characterize. Canada attributes the income to the contributor and may now want a T3; the US may see a foreign trust, kiddie tax, and PFICs if anyone involved is a US person. Here is how ITF accounts are actually taxed on both sides and when to wind one up.

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Cross-Border Tax (U.S.–Canada)

Joint Tenancy With Right of Survivorship: The Cross-Border Traps in the Simplest Estate Plan

September 13, 2026

Joint tenancy avoids probate, which is why families use it — and why it quietly creates gift tax, estate tax inclusion, deemed dispositions, and ownership disputes when the owners span the border. Here is what JTWROS actually does in each tax system, the contribution rule that surprises everyone, and when joint title costs more than the probate it saves.

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Cross-Border Tax (U.S.–Canada)

The Kiddie Tax for US Kids in Canadian Families: Whose Rate, Which Income, and How It Meets Canadian Attribution

September 13, 2026

A US-citizen child's investment income above a small threshold is taxed at the parent's US rate — even if the child lives in Canada and Canada attributes the same income to a parent. Here is how Form 8615 works when the family is cross-border, what happens when the parent is not a US person, and how the kiddie tax interacts with TOSI and attribution.

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Cross-Border Tax (U.S.–Canada)

Life Insurance Across the Border: the 1% Excise on Premiums, Section 7702, and When a Canadian Policy Misbehaves on a US Return

September 13, 2026

Life insurance is tax-favored in both countries — but each country only respects its own definition. A US person paying premiums to a Canadian insurer owes a 1% federal excise tax on each premium, and a Canadian policy that fails the section 7702 tests loses its US income tax shelter on the inside buildup. Here is the map for policies that cross the border in either direction.

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Cross-Border Tax (U.S.–Canada)

The QDOT: How a Non-Citizen Spouse Gets the Estate Tax Marital Deduction, and When the Treaty Is the Better Answer

September 13, 2026

The unlimited marital deduction — the rule that lets everything pass to a spouse estate-tax-free — is denied when the surviving spouse is not a US citizen, unless the property passes to a qualified domestic trust. Here is what a QDOT requires, the tax it defers rather than forgives, the hardship exception, and why Canadian couples often use the treaty's marital credit instead.

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Cross-Border Tax (U.S.–Canada)

An RRSP or RRIF at Death With a US-Person Beneficiary: Who Pays Canada, What the US Taxes, and the Rollover That Still Works

September 13, 2026

When an RRSP or RRIF annuitant dies, Canada wants tax on the full value — on the final return, or from the beneficiary. If the beneficiary is a US person, add withholding on cross-border payments, US income tax on the distribution, and treaty mechanics to stop the same dollars being taxed twice. Here is the sequence for spouses and for children on both sides of the border.

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Cross-Border Tax (U.S.–Canada)

Spousal Trusts for Mixed-Status Couples: Canada's Rollover Vehicle Meets the US Foreign Trust Rules

September 13, 2026

A spousal trust lets a Canadian estate defer the deemed disposition until the surviving spouse dies — control for the family, rollover for the CRA. When one spouse is a US person, the same trust is a foreign trust on the American side, with Forms 3520 and 3520-A, throwback risk, and a marital-deduction question. Here is how to design one that works in both systems.

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Cross-Border Tax (U.S.–Canada)

Streamlined Filing for Canadian Snowbirds Who Became US Tax Residents Without Knowing: The Track Problem and the Treaty Solution

September 13, 2026

A snowbird who met the substantial presence test in past years and never filed anything is a US resident for those years, but qualifies for neither streamlined track: not abroad enough for SFOP, no filed returns for SDOP. The route is usually a treaty tie-breaker position on late 1040-NRs with Form 8833, plus delinquent FBARs. Here is how it works and when it does not.

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Cross-Border Tax (U.S.–Canada)

Streamlined Filing for Married Couples: Joint Returns, Both Signatures, and the Spouse Who Isn't American

September 13, 2026

A married streamlined submission has rules for both spouses: both must meet the track's residency test, both sign the certification, and the returns are joint or separate depending on whether the other spouse is a US person. Here is how couples file, what changes when one spouse is Canadian only, and the FBAR rules for joint accounts.

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Cross-Border Tax (U.S.–Canada)

Streamlined Filing: The Real Cost for a Canadian, and What Drives It

September 13, 2026

The cost of a streamlined submission is driven by the number of returns and the forms each year requires, not by the tax. Three returns with a TFSA, a corporation, and Canadian mutual funds cost several times three plain returns. Here is what drives the fee, what the tax and interest look like, and how the 5% domestic penalty compares. Fairlight's pricing is published; this explains the ranges.

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Cross-Border Tax (U.S.–Canada)

How Does Streamlined Filing Work for Retirees With Canadian Pensions? CPP, OAS, an RPP, and a RRIF, Each on Its Own Line

September 13, 2026

A retired US person in Canada catching up through streamlined reports four kinds of Canadian retirement income differently: CPP and OAS (taxable only in Canada under the treaty), an employer pension (taxable in both with a credit), RRIF withdrawals (pension income with basis recovery), and any TFSA the retiree opened. Here is each, with the treaty positions and the forms.

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Cross-Border Tax (U.S.–Canada)

Streamlined Filing for the Self-Employed and Business Owners: Schedule C, the CPP Exemption, and the Corporation That Becomes Three Forms

September 13, 2026

A self-employed US person in Canada catching up through streamlined reports the business on Schedule C with the foreign tax credit and claims the totalization exemption from self-employment tax. A US person who runs the business through a Canadian corporation has a CFC: Form 5471 with schedules for each covered year, Subpart F and GILTI analysis, and often a section 962 election. Here is both cases.

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