Clear pricing, quoted before any work begins. Book a free fit call.

hello@fairlightaccounting.com (786) 917-4628
Fairlight Accounting Fit Call
Guides

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

1,407 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.

Capital gainsRRSPTFSADeparture taxEstate taxFBARLLCPrincipal residence
CROSS-BORDER A Canadian Corporation With a U.S. Shareholder
  • What applies to you
  • What it costs if you wait
  • What to do next

Fairlight Accounting · US + Canadian Tax Desks

1,407 guides
Cross-Border Tax (U.S.–Canada)

Canadian E-Commerce Seller in the U.S.: Amazon FBA Inventory, the Treaty's Storage Exception, State Sales Tax, and the Protective 1120-F

October 1, 2026

A Canadian company selling on Amazon's U.S. marketplace with its inventory in Amazon's U.S. fulfillment centers asks whether it now has a U.S. business: its goods sit in U.S. warehouses and ship to U.S. customers. The treaty's exception for stock kept for storage and delivery usually protects it from federal tax, the marketplace facilitator laws handle most state sales tax, but the states' income and franchise taxes, the import rules, and the protective federal filing still need attention. Here is each.

Read more →
Cross-Border Tax (U.S.–Canada)

Canadian Family Business With U.S. Heirs: The Estate Freeze, CFC and PFIC Traps, and the Succession That Crosses the Border

October 1, 2026

Canadian family businesses pass to the next generation through estate freezes, family trusts, and share transfers — and when a child lives in the United States or is a U.S. citizen, every step lands on a U.S. taxpayer: shares of a Canadian corporation that may be a controlled foreign corporation or a passive foreign investment company, a family trust that's a foreign trust, and an inheritance that triggers U.S. reporting. Here is how the standard Canadian succession tools behave for a U.S. heir, and how to plan around them.

Read more →
Cross-Border Tax (U.S.–Canada)

Canadian Professional Corporation With U.S. Clients: No Permanent Establishment, the W-8BEN-E, and the Days You Work in the U.S.

October 1, 2026

A Canadian consultant, engineer, designer, or developer billing U.S. clients through a Canadian corporation usually owes the United States nothing — the services are performed in Canada, the corporation has no U.S. permanent establishment, and the client withholds nothing if it has the right form. The exposure starts with the days worked on U.S. soil, a U.S. office, or a state that asserts nexus the treaty doesn't block. Here is the clean structure and the lines that break it.

Read more →
Cross-Border Tax (U.S.–Canada)

Canadian Trust With U.S. Beneficiaries: Form 3520, the Throwback Tax, and the Distribution That Arrives as Accumulated Income

October 1, 2026

Canadian families use trusts — family trusts holding a business's shares, testamentary trusts from an estate, alter ego and spousal trusts — and when a beneficiary lives in the United States or is a U.S. citizen, the trust is a foreign trust to the IRS. Distributions of current income are taxed simply; distributions of income the trust accumulated in earlier years trigger the throwback tax and an interest charge. Here is the U.S. beneficiary's reporting, the throwback, the grantor trust exception, and the Canadian 21-year rule's interaction.

Read more →
Cross-Border Tax (U.S.–Canada)

Cross-Border Bookkeeping: Currency, Two Sets of Rules, and the Books That Have to Satisfy the IRS and the CRA

October 1, 2026

A business with operations, owners, or filings on both sides of the border keeps books that serve two tax systems with different currencies, different depreciation, different year-ends, and different definitions of income. The books don't need to be kept twice — they need to be kept once with the reconciliations each return requires. Here is the functional currency, the exchange rate rules, the book-to-tax adjustments for each country, the intercompany accounts, and the year-end that both returns read.

Read more →
Cross-Border Tax (U.S.–Canada)

Cross-Border Intercompany Loans: Interest Withholding, Thin Capitalization, the 163(j) Limit, and Canada's Section 17

October 1, 2026

When a Canadian parent lends to its U.S. subsidiary, or a U.S. parent to its Canadian one, the loan has to satisfy both countries: the interest rate must be arm's length, the borrower's deduction may be limited by thin capitalization rules and interest caps, and the interest may carry withholding tax. A loan from the subsidiary back to the parent raises a different problem in each direction. Here is each rule and how the treaty's zero-rate on related-party interest changes the arithmetic.

Read more →
Cross-Border Tax (U.S.–Canada)

Cross-Border Management Fees Between Related Companies: Transfer Pricing, Part XIII Withholding, Regulation 105, and the Deduction Both Countries Test

October 1, 2026

When a Canadian parent charges its U.S. subsidiary for management, administration, and shared services — or a U.S. company charges its Canadian affiliate — the fee moves profit across the border, and both countries test it: the payer's country for whether the deduction is real and arm's length, the recipient's for whether it's fully reported. Canada adds a withholding tax on management fees paid to non-residents unless the treaty exempts them. Here is the pricing, the documentation, the withholding, and the substance that holds it together.

Read more →
Cross-Border Tax (U.S.–Canada)

Cross-Border Partnership With Canadian and U.S. Partners: Section 1446 Withholding, Forms 8804 and 8805, and the Canadian Partner's Return

October 1, 2026

When a U.S. partnership or LLC taxed as a partnership has a Canadian partner and earns income from a U.S. business, the partnership must withhold U.S. tax on the Canadian partner's share of that income — whether or not it distributes anything — and the Canadian partner files a U.S. return to claim the credit. When it sells, a second withholding regime applies. Here is the mechanics, the forms, the treaty's limited help, and the Canadian side, including the hybrid problem when the entity is an LLC.

Read more →
Cross-Border Tax (U.S.–Canada)

Cross-Border Retirement for Business Owners: The Individual Pension Plan, the RRSP, the Cash Balance Plan, and the Owner Who Moves

October 1, 2026

A business owner who moves between Canada and the United States takes retirement savings built under one country's rules into the other's: a Canadian owner's individual pension plan and RRSP, a U.S. owner's 401(k) and cash balance plan. The treaty recognizes most of them and defers the tax, but contributions after the move, the plan's administration across the border, and the withdrawals each need planning. Here is each plan's treatment in the other country.

Read more →
Cross-Border Tax (U.S.–Canada)

Cross-Border Stock Options and Equity Compensation: Workday Sourcing, the Canadian Deduction, the U.S. ISO, and the Employee Who Moves

October 1, 2026

Stock options and restricted stock units granted in one country and exercised or vested after the employee moves to the other are taxed by both — each country claiming the share of the benefit earned while the employee worked there. The treaty sources an option benefit by the days employed in each country between grant and exercise, Canada's stock option deduction and the U.S. incentive stock option rules don't line up, and the employer's withholding obligations follow the employee. Here is the mechanics for a Canadian moving to Florida and a U.S. employee moving to Canada.

Read more →

The content on this page is for informational purposes only and does not constitute professional tax, accounting, or legal advice. See our full legal disclaimer.