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.

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CROSS-BORDER A Canadian Corporation With a U.S. Shareholder

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1,407 guides

Cross-Border Tax (U.S.–Canada)

A Canadian Inherits a US IRA or 401(k): The Ten-Year Clock, the Withholding, and Why the Treaty Rate Needs to Be Claimed

September 18, 2026

When an American parent, sibling, or friend leaves a Canadian resident an IRA or 401(k), the beneficiary inherits a US retirement account with US rules — the ten-year distribution requirement for most non-spouse beneficiaries, 30% withholding on distributions to a nonresident alien, and a treaty rate that applies only if claimed and only to periodic payments — and a Canadian tax treatment that follows the money as it comes out. Here is what the beneficiary owns, what each country taxes, and how to take the money out efficiently.

Cross-Border Tax (U.S.–Canada)

An American Moving to Canada: The Status Options, and the Tax Obligations That Start on Each

September 18, 2026

A US citizen can visit Canada for six months without paperwork, work or study with a permit, immigrate through the economic or family programs, or — for some — claim citizenship by descent. Each status is an immigration question with a tax shadow: residency for tax purposes starts on facts, not on the permit, and the obligations in both countries begin the day the ties are established. Here is the status map with its tax start dates.

Cross-Border Tax (U.S.–Canada)

Are Americans in Canada Taxed Twice? Almost Never, and Here Is the Machinery That Stops It

September 18, 2026

The American living in Canada files two returns on the same income, and the natural fear is paying two taxes. In practice the answer is almost always no: the foreign tax credit, the treaty's allocation of taxing rights, and Canada's higher rates combine so that the US tax on Canadian income is zero for most people. The exceptions — the taxes the credit can't reach — are specific and nameable. Here is how the machinery works and where it doesn't.

Cross-Border Tax (U.S.–Canada)

Authorizing Someone to Deal With the CRA and the IRS for You: Form 2848, the CRA Representative Authorization, and What Each Actually Permits

September 18, 2026

A cross-border taxpayer needs someone who can speak to two tax authorities — and the two authorizations work differently: the IRS's Form 2848 grants representation only to credentialed practitioners for listed years and matters, with Form 8821 for information-only access; the CRA's authorization is granted online to anyone with a representative ID, at a chosen level, until cancelled. Here is what each form does, who can be named, and the setup that lets one advisor handle both sides.

Cross-Border Tax (U.S.–Canada)

Before You Hire a Cross-Border Accountant: Why a Written Position Review First Saves the Engagement You Don't Need

September 18, 2026

Most cross-border tax engagements start with the wrong question — 'can you do my returns?' — before anyone has established which returns, which years, which elections, and whether the situation is a two-form annual filing or a six-year repair. A short written review of where you actually stand, done before any preparation is engaged, answers those questions once and prices the real work. Here is what a position review covers, what it is not, and how to use it.

Cross-Border Tax (U.S.–Canada)

Buying From a Non-Resident Seller in Canada: The 25% You Must Hold Back, the Section 116 Certificate, and the Buyer Who Gets Stuck With the Tax

September 18, 2026

Section 116 is usually described from the seller's side — the clearance certificate a non-resident obtains when selling Canadian real property. From the buyer's side it is a liability: unless the seller produces the certificate, the buyer must withhold 25% of the purchase price and remit it to the CRA, and a buyer who neither withholds nor makes reasonable inquiry owes the seller's tax personally. Here is the buyer's obligation, the inquiry that protects them, and how closings handle it.

Cross-Border Tax (U.S.–Canada)

California and Your Retirement Withdrawals After Leaving: The Federal Law That Stops Source-State Pension Tax

September 18, 2026

Former California residents retiring in Canada often assume — or are warned — that California will tax their 401(k) and IRA withdrawals because the accounts were built there. It won't, and it can't: a federal statute prohibits any state from taxing the retirement income of a nonresident, regardless of where the income was earned. Here is the law, what it covers and what it doesn't, the residency break that has to be real for it to apply, and the California-specific items that survive the move.

Cross-Border Tax (U.S.–Canada)

Canadian Students on F-1 and OPT: The Exempt-Individual Years, the Year the Day Count Starts, and What Changes on the Return

September 18, 2026

A Canadian on an F-1 student visa, then on Optional Practical Training, is physically in the US for years without being a US tax resident — because student days are exempt from the substantial presence test for five calendar years. The sixth year, or the year the visa changes to H-1B, the count starts, and the return changes from a 1040-NR to a 1040 with worldwide income. Here is the exempt-individual rule, the year residency begins, and the Canadian side that runs alongside.

Cross-Border Tax (U.S.–Canada)

Check-the-Box on a Canadian Corporation Before Moving to the US: Why Only a ULC Can, and What the Election Costs and Saves

September 18, 2026

Canadians moving to the US with a corporation ask whether they can elect to have it disregarded for US tax — avoiding the controlled foreign corporation regime entirely. The answer is that an ordinary Canadian corporation cannot: it is a per se corporation. An unlimited liability company can. Here is how the conversion-and-election sequence works, the treaty hybrid rule it triggers, and when the whole exercise is worth it.

Cross-Border Tax (U.S.–Canada)

Claiming Canadian Citizenship Through a Parent or Grandparent: What Changes on Your Taxes, and What Doesn't

September 18, 2026

Americans with a Canadian parent — and, under the expanded descent rules, some with a Canadian grandparent — can claim Canadian citizenship by descent and receive a certificate confirming it. The tax consequences are smaller than most expect: Canada taxes residents, not citizens, so a new Canadian citizen living in the US owes Canada nothing new. What does change are the doors the citizenship opens — and the treaty and estate rules that key off citizenship in specific places. Here is the sort.

Cross-Border Tax (U.S.–Canada)

Combining CPP and Social Security Work Credits: How the Totalization Agreement Qualifies You, and What It Pays

September 18, 2026

Social Security requires forty quarters of covered work; CPP requires contributions in Canada. A career split between the countries can leave a worker short in one system — and the Canada-US totalization agreement exists to fix exactly that: credits from one country fill the eligibility gap in the other, and the resulting benefit is prorated to the share actually earned there. Here is how the agreement qualifies split-career workers, what it pays, and its coverage rules for people working across the border.

Cross-Border Tax (U.S.–Canada)

Crypto on a Canadian and a US Return: Disposition Rules, Cost Base Methods, Staking Income, and the Reporting Forms on Each Side

September 18, 2026

Both countries tax cryptocurrency as property, not currency — every sale, swap, or purchase with crypto is a disposition — but they diverge on cost base (Canada averages; the US identifies lots), on the character of gains (Canada's business-versus-capital analysis; the US's capital default), on staking and mining, and on the reporting forms. The cross-border holder computes twice from one transaction history. Here is each system's rules, where they diverge, and the record system that serves both.

Cross-Border Tax (U.S.–Canada)

Departure Tax Paid to Canada, Gain Taxed Again in the US? The Treaty Election That Resets Your US Basis

September 18, 2026

Canada taxes your accrued gains when you leave; the US, when you arrive, keeps your historical cost basis — so a later US sale taxes the same pre-departure gain a second time with no Canadian tax to credit that year. The treaty's departure election fixes it: you may elect to treat the property as sold and reacquired for US purposes at the same value Canada used, aligning the two countries' basis. Here is the election, which property it covers, how it's made, and what happens without it.

Cross-Border Tax (U.S.–Canada)

ESPP Shares After Moving to Canada: The Discount the US Still Taxes, the Gain Canada Measures From Arrival, and the Sale That Straddles Both

September 18, 2026

Employee stock purchase plan shares bought at a discount during US employment and sold after a move to Canada are taxed by two systems that disagree about what the discount is, when it's taxed, and where the gain starts. The US treats part of the sale as compensation sourced to US workdays; Canada measures the gain from the arrival-date value. Here is how a qualified ESPP is taxed on each side, the arrival basis, and the sale computation.

Cross-Border Tax (U.S.–Canada)

FAPI: Why Canada Taxes a Canadian Resident on a US Corporation's Passive Income Before Any Dividend Is Paid

September 18, 2026

Canada's mirror of Subpart F is foreign accrual property income: a Canadian resident who controls a foreign corporation — a US C corporation, or a US LLC Canada sees as a corporation — is taxed in Canada on the corporation's passive income as it is earned, with a deduction for the foreign tax the corporation paid. Active business income is exempt. Here is what FAPI catches, how the foreign-tax deduction works, and the US structures that generate it by accident.

Cross-Border Tax (U.S.–Canada)

Form T1134 for a Canadian Who Owns a US Corporation or LLC: The Foreign Affiliate Report, Its Thresholds, and the Dormant-Company Exception

September 18, 2026

Canada's counterpart to Form 5471 is the T1134: an annual information return for every foreign affiliate a Canadian resident owns, including the US LLC that Canada treats as a corporation. It is due ten months after year-end, carries daily penalties, and is widely missed by Canadians whose US structures were set up by US advisors. Here is who files, what it discloses, and the exception that spares small dormant companies.

Cross-Border Tax (U.S.–Canada)

Forms NR73 and NR74: Whether to Ask the CRA to Rule on Your Residency, and Why Most Advisors Say Don't

September 18, 2026

The CRA offers two forms — NR73 for people leaving Canada, NR74 for people entering — that ask for an opinion on your residency status. They are optional, the opinion is not binding, and the questionnaire hands the CRA a detailed inventory of your ties. Most cross-border advisors recommend against filing them, with a short list of exceptions. Here is what the forms do, when the opinion helps, and how residency is established without them.

Cross-Border Tax (U.S.–Canada)

Getting 15% Instead of 30% Withheld on Your US Retirement Withdrawals From Canada: The W-8BEN Treaty Claim Your Custodian Needs

September 18, 2026

A Canadian resident drawing from a US IRA or 401(k) is a nonresident alien to the plan, and the default withholding on pension distributions to nonresident aliens is 30%. The treaty caps US tax on periodic pension payments at 15% — but only if the custodian has a valid W-8BEN claiming it, and only for payments that qualify as periodic. Here is the claim, the periodic-versus-lump-sum line, and how to structure withdrawals so the cap applies.

Cross-Border Tax (U.S.–Canada)

Getting a US Employer Identification Number From Canada: Who Needs One, the SS-4 Without an SSN, and the Phone Route

September 18, 2026

A Canadian business or individual dealing with the US often needs an Employer Identification Number — to open a US bank account, run US payroll, form a US entity, file a US return, or complete a W-8BEN-E treaty claim. The online application requires a Social Security number or ITIN the applicant doesn't have; the SS-4 by phone or fax does not. Here is who needs an EIN, who doesn't, and how to get one from outside the US in a week.

Cross-Border Tax (U.S.–Canada)

GILTI Has a New Name: What the Renamed Regime Changes for a US Citizen's Canadian Corporation, and What Stays the Same

September 18, 2026

The 2025 US tax legislation renamed global intangible low-taxed income as net CFC tested income and adjusted its arithmetic: the deduction shrank, the foreign tax credit allowance grew, and the deemed return on tangible assets disappeared. For a US citizen who owns a Canadian corporation, the mechanics that matter — the high-tax exclusion, the section 962 election, the Form 5471 machinery — mostly survive under the new label. Here is what changed, what didn't, and how to read the new acronyms.

Cross-Border Tax (U.S.–Canada)

Giving Up a Green Card to Move Back to Canada: The Eight-Year Rule, the Exit Tax Tests, and Form 8854 for Long-Term Residents

September 18, 2026

A Canadian who held a US green card long enough — eight of the last fifteen years — is a long-term resident, and abandoning the card is an expatriation event with the same exit-tax regime that applies to citizens who renounce: a deemed sale of worldwide assets, the covered-expatriate tests, and Form 8854. A shorter holding period escapes the regime entirely. Here is the eight-year rule, the tests, the treaty position that can trigger expatriation unintentionally, and the sequence for a clean exit.

Cross-Border Tax (U.S.–Canada)

How Much More Tax Do You Really Pay in Canada? Federal, Provincial, and State Rates Compared at Real Incomes

September 18, 2026

The rate comparison everyone wants is harder than a table of brackets: Canada stacks federal and provincial rates on the same base; the US stacks federal and state rates with different deductions, filing statuses, and payroll taxes; and the two countries treat capital gains, dividends, and healthcare completely differently. Here is the comparison done properly — combined marginal and effective rates at real incomes, by province and state, with the payroll and healthcare layers that change the answer.

Cross-Border Tax (U.S.–Canada)

Inheriting From Someone Who Renounced: The Section 2801 Tax on Gifts and Bequests From Covered Expatriates

September 18, 2026

When a covered expatriate — a former US citizen or long-term resident who met the exit-tax tests — later gives or leaves money to a US person, the recipient owes a tax at the highest estate tax rate on what they received. The rule waited fifteen years for regulations and a form; both now exist, and Form 708 is due for gifts and bequests received from 2025 on. Here is who is caught, what is taxed, the exceptions, and why a Canadian family with a renounced member should read the expatriate's Form 8854.

Cross-Border Tax (U.S.–Canada)

Investing in Canada as a US Citizen Without PFIC Trouble: Individual Stocks, US-Listed Funds, and Where Canadian Funds Are Still Safe

September 18, 2026

The passive foreign investment company rules turn ordinary Canadian mutual funds and ETFs into a US tax and reporting burden — annual Form 8621s, punitive default taxation, elections with conditions. The rules are avoidable by construction: individual securities, US-listed funds, and accounts the rules don't reach. Here is what a US citizen in Canada can hold without the regime, where Canadian funds are still fine, and how to rebuild a portfolio around the constraint.

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