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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)

State Tax After Streamlined Filing: What the IRS Program Doesn't Cover, and the States That Notice

September 7, 2026

The streamlined procedures are federal. A taxpayer who was a resident of a US state during the covered years, or who had state-source income, has state returns to file or amend, state penalties that the IRS program does not waive, and in some states a voluntary disclosure program of its own. Here is which taxpayers have a state problem and what to do about it.

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Cross-Border Tax (U.S.–Canada)

The Streamlined Domestic Penalty: What Is the 5% Actually 5% Of? The Assets That Were Never Reported, at Their Highest Year-End Value

September 7, 2026

The domestic streamlined procedure charges a 5% miscellaneous offshore penalty. It is not 5% of the income, the tax, or everything foreign; it is 5% of the highest aggregate year-end value of the foreign financial assets that should have been reported and were not, across the six FBAR years and three return years. Here is how the base is built, what is excluded, and how a Canadian mover's RRSP usually escapes it.

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Cross-Border Tax (U.S.–Canada)

Streamlined Filing With PFICs: Canadian Mutual Funds Add a Form 8621 for Every Fund for Every Year

September 7, 2026

A US person catching up through streamlined who holds Canadian mutual funds or Canadian-listed ETFs has passive foreign investment companies, and each requires Form 8621 for each year in the submission. Here is how the PFIC rules apply in a catch-up, the elections available and not available late, the excess distribution computation, and the plan to end the problem afterward.

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Cross-Border Tax (U.S.–Canada)

Streamlined vs. Voluntary Disclosure: When Willfulness Changes the Calculus

September 7, 2026

The streamlined procedures require non-willful conduct and carry no penalty (foreign) or 5% (domestic). The Voluntary Disclosure Practice is for conduct that may have been willful, and under its current terms it costs failure-to-file and accuracy-related penalties plus per-year FBAR penalties, in exchange for protection from criminal referral. Here is how willfulness is judged, how the two routes compare, and how to decide when the facts are mixed.

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Cross-Border Tax (U.S.–Canada)

Tax Equalization for Cross-Border Relocations: What the Policy Promises, What the Hypothetical Tax Misses, and How to Check the Settlement

September 7, 2026

Tax equalization keeps a relocated employee's tax burden at what it would have been at home, with the employer absorbing the difference. Here is how equalization and protection policies work between Canada and the US, what the hypothetical tax typically omits, and how to audit the year-end settlement.

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Cross-Border Tax (U.S.–Canada)

Proving Where You Live for Tax Purposes: Form 8802 for a US Residency Certificate, and the CRA's Certificate of Residency

September 7, 2026

A tax residency certificate proves to a foreign tax authority that you are a resident of your country for treaty purposes. Americans get Form 6166 by filing Form 8802 with the IRS; Canadians get a certificate of residency from the CRA. Here is when each is needed, how to apply, and what they do and do not prove.

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Cross-Border Tax (U.S.–Canada)

Transfer Pricing Between Canada and the US: Arm's-Length Prices for Related-Party Transactions, and the Documentation Both Sides Expect

September 7, 2026

When a Canadian company and its US affiliate buy, sell, lend, license, or provide services to each other, both tax authorities require arm's-length prices. Here is what transfer pricing means for a small cross-border group, the documentation each country requires, the penalties, and the methods that work.

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Cross-Border Tax (U.S.–Canada)

My Unreported Income Was Employment Income, Not Account Income. Do I Still Need Streamlined? Usually Yes, Because There Is Almost Always an Account

September 7, 2026

The streamlined procedures are framed around foreign financial assets, and a person whose only omission was a Canadian salary wonders if they belong. In practice, the salary was deposited in a Canadian account whose interest was also unreported, and that account puts the file in the program. Here is the eligibility language, the edge case with truly no foreign assets, and what to file in each.

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Cross-Border Tax (U.S.–Canada)

The Treaty Tie-Breaker, Test by Test: Permanent Home, Centre of Vital Interests, Habitual Abode, Citizenship, and What the CRA and IRS Look For

September 7, 2026

A test-by-test walk through Article IV(2) of the Canada-US tax treaty: what counts as a permanent home, how the centre of vital interests is weighed, when habitual abode decides, the citizenship step, and competent authority. With the evidence each agency asks for and the fact patterns that go each way.

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Cross-Border Tax (U.S.–Canada)

US Estate Tax on a Canadian's Florida Vacation Rental: The $60,000 Threshold, the Treaty Proration, and the Form 706-NA That Makes It Zero

September 7, 2026

A Canadian who dies owning a Florida rental is subject to US estate tax on it above $60,000 under US law. The treaty prorates the full US exemption by the US share of the worldwide estate, which eliminates the tax for most Canadians, but only on a Form 706-NA filed within nine months. Here is the calculation, the marital credit, the mortgage, and the alternatives.

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Cross-Border Tax (U.S.–Canada)

W-8BEN-E: What a Canadian Corporation Files to Stop US Withholding, and the Limitation-on-Benefits Box That Trips It Up

September 7, 2026

When a Canadian corporation earns US-source income (royalties, service fees, dividends, interest), the US payer withholds 30% unless the corporation provides Form W-8BEN-E claiming treaty benefits. Here is how to complete it, which chapter 3 and chapter 4 statuses apply, the limitation-on-benefits certification, and what to do when it was not filed.

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Cross-Border Tax (U.S.–Canada)

What Happens After a Streamlined Filing? No Letter, a Normal Statute, and What Audit Risk Actually Looks Like

September 7, 2026

A streamlined submission produces no acknowledgment. The returns are processed, the statute of limitations starts, and the file is subject to ordinary examination selection like any other. Here is what to expect in the months after, what an examination of a streamlined year looks like, and the compliance that keeps the file quiet.

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