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 gains RRSP TFSA Departure tax Estate tax FBAR LLC Principal residence

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

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1,407 guides

Cross-Border Tax (U.S.–Canada)

Keeping Your Canadian Job After Moving to the US: Who Withholds, Whether CPP Continues, and When the Employer Needs a US Payroll

September 18, 2026

An employee who moves to the US and keeps working remotely for a Canadian employer has changed the tax character of every paycheque: the salary is now earned in the US by a non-resident of Canada, which takes it out of Canada's tax base, puts it squarely in the US's, and leaves the Canadian employer running a payroll that no longer fits. Here is what should happen to withholding, CPP and EI, and the employer's obligations — and why most Canadian employers get it wrong for a year.

Cross-Border Tax (U.S.–Canada)

Kept Your Canadian Clients After Moving to the US? Which Country Taxes the Fees, and Whether Regulation 105 Applies to You Now

September 18, 2026

A consultant who moves to the US and keeps billing Canadian clients from there has become, in Canada's eyes, a non-resident providing services — usually from outside Canada, which changes everything about who taxes the fees. Regulation 105 withholding applies only to services performed in Canada; the treaty protects business profits without a Canadian permanent establishment; and the US now taxes the income as a resident's worldwide earnings. Here is the sort, by where the work is done.

Cross-Border Tax (U.S.–Canada)

Moving a 401(k) or IRA Into an RRSP: The Paragraph 60(j) Rollover, the US Withholding That Leaks, and When It Is Worth It

September 18, 2026

Canada lets a returning or arriving resident move a US retirement plan into an RRSP without using contribution room, through a deduction under paragraph 60(j) that offsets the income inclusion. The catch is on the US side: the distribution is taxed and withheld by the US, the withheld amount never reaches the RRSP unless replaced from other funds, and the US tax often cannot be credited because the Canadian deduction leaves nothing to credit against. Here is the mechanism, the leak, and the cases where the transfer still wins.

Cross-Border Tax (U.S.–Canada)

Moving Back to Canada With a Florida Home: Sell Before the Move or After? The Two Exemptions and the Arrival Step-Up Decide

September 18, 2026

A Canadian returning home after years in the US, still owning the Florida house, has a timing decision: sell while a US resident (the section 121 exclusion, no Canadian tax, no FIRPTA) or sell after becoming a Canadian resident (Canada's arrival step-up shelters the pre-return gain, the US exclusion may still apply, but FIRPTA withholding and non-resident mechanics arrive). Here is the comparison, the windows that decide it, and the version where keeping the house as a rental changes everything.

Cross-Border Tax (U.S.–Canada)

Moving to the US on an E-2 Visa: The Canadian Departure, the Business Entity, and the First-Year Returns on Both Sides

September 18, 2026

The E-2 investor's move differs from the TN or H-1B employee's in one way that reshapes the tax year: the investor arrives owning a US business, having moved capital into it, and often having sold or wound down a Canadian one. Year one combines the departure file, the investment's cross-border funding, the entity's first return, and a dual-status personal return. Here is the sequence, and the traps that recur.

Cross-Border Tax (U.S.–Canada)

One Spouse in the US, One Still in Canada: Residency for Each, the Filing Status Each Country Allows, and the House Between You

September 18, 2026

A job takes one spouse to the US while the other stays in Canada with the house, the kids, or a career — and the couple's tax residency splits. Each spouse is tested separately; each country offers filing statuses that assume the other spouse is somewhere specific; and the family home, held by both, sits in two residency analyses at once. Here is how the split couple is taxed, the elections available, and the traps in the year they diverge.

Cross-Border Tax (U.S.–Canada)

Owning US S-Corporation or Partnership Interests From Canada: Flow-Through to the IRS, a Corporation or Partnership to the CRA

September 18, 2026

A Canadian resident holding an interest in a US S corporation or partnership faces a characterization gap: the US taxes the income as it flows through to the owner; Canada may see a corporation (the S corporation) or a partnership (the LLC or LP) and tax on its own timing and character. Add the S corporation eligibility rule that bars nonresident aliens, and the Canadian owner's position is more fragile than it looks. Here is how each structure is taxed on both sides.

Cross-Border Tax (U.S.–Canada)

Paid Departure Tax, Then the Asset Fell: The Loss Carryback Election That Refunds Part of It

September 18, 2026

Departure tax is computed on the fair market value the day you leave. If the property later sells for less — the private company that stumbled, the portfolio that dropped — you paid Canadian tax on a gain that never materialized. The Income Tax Act allows an emigrant who sells deemed-disposed property at a loss while non-resident to elect to reduce the departure-year deemed proceeds, generating a refund. Here is the election, its limits, and the sequence.

Cross-Border Tax (U.S.–Canada)

Part XIII Withholding After You Leave Canada: The 25% Default, the Payments It Hits, and the Treaty Rates That Replace It

September 18, 2026

The day you become a non-resident of Canada, your Canadian income stops being taxed by return and starts being taxed at source: Part XIII of the Income Tax Act imposes a flat 25% on dividends, interest, rent, pensions, RRSP and RRIF payments, and other passive income paid to non-residents — collected by the payer, final in most cases, and reduced by the treaty only when the payer knows to apply it. Here is the regime, payment by payment, and the declarations and elections that manage it.

Cross-Border Tax (U.S.–Canada)

Putting US Income on a Canadian T1: Which Lines, Which Exchange Rate, and How the Foreign Tax Credit Is Claimed

September 18, 2026

A Canadian resident with US income — a salary from a US employer, dividends from a US brokerage, a US pension, a Florida rental — reports every dollar on the T1 in Canadian dollars and claims a credit for the US tax on it. The mechanics are line-specific, the conversion rules have options, and the credit is computed separately for business and non-business income with a provincial layer. Here is the map from each US slip to the Canadian return.

Cross-Border Tax (U.S.–Canada)

Refundable Dividend Tax on Hand When the Shareholder Files a 1040: Why Canada's Refund Mechanism Does Nothing for the US Side

September 18, 2026

Canada's integration system taxes a private corporation's investment income at a high rate, then refunds part of it when dividends are paid — so that the shareholder ends up roughly where they would have been earning the income directly. A US-citizen shareholder gets the Canadian refund and none of the integration: the IRS taxes the dividend on its own terms, may have already taxed the underlying income, and gives no credit for tax that was refunded. Here is how the two systems collide.

Cross-Border Tax (U.S.–Canada)

Reading an NR4 for Your 1040: Which Box Is Income, Which Is Withholding, and Where Each Goes

September 18, 2026

The NR4 is the slip a Canadian payer issues to a non-resident — the US-resident former Canadian's RRIF payments, dividends, rent, and pension arrive on it — and it looks nothing like a 1099. The income code decides what kind of income it is, the gross amount goes on the 1040 by type, and the tax withheld is a foreign tax credit, never US withholding. Here is the slip decoded, box by box, and the three errors US preparers make with it.

Cross-Border Tax (U.S.–Canada)

Retire in Canada or in the US? The Tax Comparison for Dual Citizens, Account by Account

September 18, 2026

A dual citizen approaching retirement with assets in both countries can choose where to live — and the choice reorders the tax on every account, because the treaty taxes most retirement income in the country of residence. The comparison is not 'Canada is higher' or 'the US is lower'; it is account by account, with healthcare, estate rules, and currency as the tiebreakers. Here is the framework, the per-account results, and the profiles for which each country wins.

Cross-Border Tax (U.S.–Canada)

Retiring to Canada From the US: The Tax Picture for Social Security, IRAs, Medicare, and the Estate

September 18, 2026

An American retiring to Canada carries a US retirement architecture — Social Security, IRAs and 401(k)s, Medicare, a will drafted for one country — into a system that taxes each piece on its own terms, with the treaty deciding who taxes what. The result is usually workable and rarely intuitive. Here is how each component is treated after the move, the arrivals-year decisions, and the estate questions a US-drafted plan doesn't answer.

Cross-Border Tax (U.S.–Canada)

Returning to Canada After Years in the US: The Re-Entry Checklist for Your IRA, US Home, State Residency, and Arrival Basis

September 18, 2026

The returning Canadian is a newcomer with a history: US retirement accounts, perhaps a US home, a state to leave, an old departure-tax file to reopen, and RRSP room that survived the absence. The re-entry runs the newcomer rules in one direction and the departure rules in reverse. Here is the checklist, ordered by what has to happen before the border and what can wait for the first return.

Cross-Border Tax (U.S.–Canada)

Returning to Canada With Property You Still Own: The Election That Unwinds Your Old Departure Tax

September 18, 2026

Departure tax treats emigration as a sale — you paid Canadian tax on gains you never realized. If you come back still owning that property, the Income Tax Act lets you elect to undo the deemed disposition: the property is treated as never having been sold on departure, the tax you paid is refunded, and the original cost base is restored. Here is how the unwind works, which property qualifies, the interaction with any security you posted, and why the old departure file is the key.

Cross-Border Tax (U.S.–Canada)

Roth Conversions Before a Move to Canada: Why the Window Closes at the Border, and How to Size One

September 18, 2026

Converting a traditional IRA to a Roth is a US-resident's decision that becomes a Canadian-resident's problem the day after the move: a conversion made while resident in Canada is a Canadian contribution that taints the Roth's treaty protection and is taxable in Canada as well as the US. Conversions belong before the border — sized to the US brackets of the final US years, and paid from outside the account. Here is the analysis and the sequence.

Cross-Border Tax (U.S.–Canada)

RRSP and 401(k) Compared: Contribution Rules, Treaty Treatment, and What Each Becomes When You Cross the Border

September 18, 2026

The RRSP and the 401(k) are cousins — tax-deferred retirement accounts funded from earned income — and the cross-border mover treats them as interchangeable at their peril. Contribution mechanics, employer involvement, withdrawal rules, and the treaty's treatment of each in the other country differ in ways that decide whether to keep, collapse, or transfer. Here is the side-by-side, and what each account turns into after a move.

Cross-Border Tax (U.S.–Canada)

The Section 962 Election for a US Citizen Who Owns a Canadian Corporation: Corporate Rates on GILTI, and the Dividend Catch Later

September 18, 2026

An individual US shareholder of a Canadian corporation is taxed on its tested income at individual rates with no foreign tax credit for the corporation's Canadian tax — the worst of both worlds. Section 962 lets the individual elect to be taxed as if a corporation on those inclusions: corporate rate, the participation-style deduction, and a credit for the corporation's taxes. The price is paid when the earnings come out. Here is the election, its arithmetic, and who should make it.

Cross-Border Tax (U.S.–Canada)

Sell the Canadian Business Before You Move or After? The Capital Gains Exemption, the CFC Rules, and the Answer That Depends on the Buyer

September 18, 2026

A business owner moving to the US with a sale in view faces a timing decision worth six or seven figures: sell as a Canadian resident and use the lifetime capital gains exemption, or sell after the move and face departure tax on the shares, US tax on the gain, and a year or more inside the CFC regime. The clean answer is usually 'before' — unless the buyer, the deal structure, or the exemption's qualification tests say otherwise. Here is the analysis.

Cross-Border Tax (U.S.–Canada)

Selling a Short-Term Rental You Ran From Across the Border: Recapture, Withholding, Lodging-Tax Close-Out, and the Order to Do It In

September 18, 2026

A cross-border short-term rental exits through more regimes than it entered: depreciation recapture in the country that allowed it, capital gains in both, FIRPTA or section 116 withholding for the non-resident seller, a possible GST/HST hit on a heavily rented Canadian property, and the lodging-tax and platform accounts that have to be closed properly. The order matters — several steps must precede the listing. Here is the exit checklist, both directions.

Cross-Border Tax (U.S.–Canada)

Structuring an E-2 Business as a Canadian: Why the LLC Fails Twice and the C Corporation Usually Wins

September 18, 2026

The E-2 treaty investor visa requires a real US business you own and direct — and the entity you form for it decides your tax life on both sides of the border. Immigration lawyers default to the LLC; for a Canadian who remains connected to Canada, that default creates a corporation-to-Canada mismatch and a self-employment tax bill. Here is how the LLC and C corporation compare for the E-2 investor, and the residency question that decides between them.

Cross-Border Tax (U.S.–Canada)

Subpart F Inside a Canadian Corporation: The Passive Income the IRS Taxes Immediately, and How It Differs From GILTI

September 18, 2026

A US citizen who controls a Canadian corporation has two anti-deferral regimes running at once: Subpart F, which taxes the corporation's passive income to the shareholder in the year earned, and the tested-income regime that reaches the rest. For most Canadian operating companies, Subpart F is the smaller problem — until the retained earnings get invested. Here is what Subpart F catches, the high-tax exception that usually turns it off, and how it fits beside the other regime.

Cross-Border Tax (U.S.–Canada)

TFSA and Roth IRA: Look-Alike Accounts That Each Country Refuses to Recognize From the Other

September 18, 2026

The TFSA and the Roth IRA are the same idea — after-tax contributions, tax-free growth, tax-free withdrawals — implemented by two countries that don't honor each other's version. A Canadian's TFSA is a taxable account to the IRS; an American's Roth IRA is protected in Canada only by a treaty election most people never file. Here is how each account is treated by the other country, the elections and traps, and what a mover should do with each.

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