Canada-US Cross-Border Tax: Every Topic Guide, Organized by Situation

Fairlight's topic guides cover the mechanics of cross-border tax between Canada and the US. Each guide explains one rule, one form, or one situation — how the substantial presence test counts your days, what the RRSP does on a US return, when a Canadian has to file a 1040-NR, which treaty article exempts a royalty — with a worked example and links to the official CRA, IRS, and treaty sources behind it. They are written for the person in the situation: the American in Toronto with a TFSA, the Canadian moving to Austin with a corporation, the snowbird counting winters, the executive on a New York assignment.

This page organizes every topic guide by situation. If you are moving, planning a cross-border life, or filing in both countries and want the rule behind a number on your return, start here. For the location-by-location moving guides — every city, province, and state corridor — see the Canada-US moving guides by city, province, and state.

Cross-border basics explained

Short definitional guides to the forms and terms that come up first — each links to the long-form guides below.

• CRA Represent a Client, explained
• RSP vs. RRSP: what the terms mean
• RRIF minimum withdrawals: the table and the rules
• The Canadian dividend tax credit, explained
• Adjusted cost base (ACB), explained
• Is inheritance taxable in Canada?
• Form NR301, explained
• Form NR73: leaving Canada and the residency determination
• Form T1135: the foreign income verification statement
• TFSA vs. Roth IRA across the border
• W-9 vs. W-8BEN for Canadians
• The Canadian individual tax number (ITN) for non-residents
• The Canada–U.S. tax treaty, explained
• Severance pay in Canada: the retiring allowance
• Form T776 rental income and the section 216 election
• Does Canada have a 1099? The T4A and NR4, explained

International forms and rules explained

• Substantial Presence Test: How Days Make You a U.S. Resident
• Form 8840: The Closer Connection Exception for Snowbirds
• Form 1040-NR Explained: The U.S. Return for Nonresidents
• Form 8833: Disclosing a Treaty-Based Return Position
• FIRPTA Withholding Explained for Foreign Sellers
• Form 3520 Explained: Foreign Trusts, Gifts, and Inheritances
• What Is a PFIC? Passive Foreign Investment Companies
• What Is a Controlled Foreign Corporation (CFC)?
• Form 5471 Explained: U.S. Owners of Foreign Corporations
• Subpart F Income Explained: Passive Income in a CFC
• GILTI Explained for Owners of Canadian Corporations
• Section 962 Election Explained: Corporate Rates for You
• Form 5472 Explained: Foreign-Owned U.S. Companies and LLCs
• Branch Profits Tax Explained for Canadian Companies
• Expatriation Tax Explained: Renouncing U.S. Citizenship
• Canada–U.S. Totalization Agreement Explained

For individuals and families

• What Is the FBAR? Reporting Foreign Bank Accounts
• Form 8938 Explained: FATCA Foreign Asset Reporting
• U.S. Citizens Living in Canada: What You File Each Year
• Accidental Americans: U.S. Citizens Who Didn't Know It
• Foreign Earned Income Exclusion Explained: Form 2555
• Form 1116 Explained: The Foreign Tax Credit for Individuals
• Streamlined Filing Compliance Procedures Explained
• Moving From Canada to the U.S.: Your First U.S. Tax Year
• Dual-Status Return Explained: The Year You Move
• Nonresident Spouse Election: Filing Jointly With a Canadian
• ITIN Explained: Form W-7 for Canadians and Spouses
• Canada Child Benefit When You Move to the U.S.
• Canadian Departure Tax Explained: The Deemed Sale
• Section 217 Election: Canadian Pensions for Non-Residents
• Old Age Security for Non-Residents of Canada Explained
• U.S. Estate Tax for Canadians: U.S. Property at Death

Property and investment income

• Florida Homestead Exemption: Can Canadians Claim It?
• Section 116 Certificate: Selling Canadian Property
• Selling a Canadian Home as a U.S. Citizen
• Underused Housing Tax Explained for Non-Resident Owners
• Form W-8ECI Explained: Effectively Connected Income
• Section 871(d) Election: U.S. Rent Taxed on the Net
• Qualified Dividends From Canadian Companies Explained
• U.S. Social Security for Canadian Residents
• Form 1042-S Explained: The U.S. Slip Canadians Receive
• Part XIII Withholding Explained: Canada's Non-Resident Tax
• RESPs for U.S. Citizens: The Cross-Border Problem
• Article XIII(7) Election: Stepping Up Basis After a Move
• Form 8843 Explained: Canadian Students and Exempt Days

Canadian-side business forms

• Form T1134 Explained: Canadians With Foreign Affiliates
• Form T106 Explained: Related-Party Non-Resident Deals
• FAPI Explained: Canada's Tax on Foreign Passive Income

Canadian-side rules and forms

• Canadian Alternative Minimum Tax Explained
• Canadian Foreign Tax Credit Explained: Form T2209
• Canadian Tax Instalments Explained for Individuals
• Canadian Tax Return for Non-Residents Explained
• Capital Gains Inclusion Rate in Canada Explained
• Deemed Residency in Canada: The 183-Day Sojourner Rule
• Factual Residency in Canada: The Residential Ties Test
• First Home Savings Account for U.S. Citizens in Canada
• Form NR6 Explained: Net Withholding on Canadian Rent
• Form T2091: Designating a Principal Residence
• Form T2125 Explained: Canadian Business Income
• Forms T1141 and T1142: Non-Resident Trusts
• Lifetime Capital Gains Exemption Explained
• Regulation 105 Waiver Explained: Form R105
• RRSP Over-Contribution Explained: The 1 Percent Tax
• TFSA for Non-Residents: What Changes When You Leave Canada

Moving between Canada and the U.S.

• Canadian Retirees in Florida: Who Taxes What
• Canadian Snowbird Six-Month Rule and U.S. Registration
• E-2 Visa Taxes: Canadian Investors in a U.S. Business
• First-Year FBAR and Form 8938 for New U.S. Residents
• Green Card Abandonment and the Exit Tax
• Green Card Holder Tax Obligations Explained
• H-1B Visa Taxes for Canadians
• L-1 Visa Taxes: Intracompany Transfers From Canada
• Moving Back to Canada From the U.S.: Tax Basics
• Pension Income Splitting After Moving to the U.S.
• Pre-Immigration Tax Planning for Canadians
• Sailing Permit Explained: Forms 1040-C and 2063
• Spousal RRSP After Moving to the U.S.
• SSN or ITIN: Tax Numbers for New U.S. Residents
• TN Visa Taxes: Canadians Working in the U.S.
• Why Canadians Choose Florida: State Tax Compared

Residency and the treaty

• How the CRA decides whether you are a Canadian tax resident
• The substantial presence test: the weighted 183-day formula
• The closer connection exception: Form 8840 for snowbirds
• Resident of both countries? How the treaty tie-breaker decides
• The treaty tie-breaker, test by test
• Your tax home: what the IRS means by it
• Proving where you live: Form 8802 and the CRA certificate of residency
• The green card holder living in Canada
• Renouncing Canadian citizenship: why it changes almost nothing
• Renouncing US citizenship: the covered expatriate tests and exit tax
• Your child born in Canada to a US citizen parent

Moving to the US

• Your first US tax return after moving from Canada: the twelve items
• Pre-move tax planning: the twelve-month timeline in both directions
• H-1B and L-1 in the first US year: the dual-status math
• J-1 visa tax for Canadians: exempt individual status
• Form W-4 for a Canadian working in the US
• Provincial health insurance when you leave Canada
• Keeping Canadian bank accounts after moving to the US
• Cost basis and adjusted cost base: two costs at the border
• Capital losses that don't cross the border
• Moving expenses: why neither country deducts them

Americans in Canada

• The American living in Canada: what you still owe the IRS
• The foreign earned income exclusion for Americans in Canada
• The bona fide residence test and the FEIE
• Foreign tax credit carryforward and carryback (Form 1116)
• When the foreign tax credit doesn't cover it all
• Standard deduction or itemize? The cross-border filer's choice
• Reporting Canadian income on a US return: where each slip goes
• Self-employment tax for US citizens in Canada: CPP, not both
• Getting married across the border: filing status and the joint return
• Medical expenses across the border
• Tuition across the border: Canada's credit and the AOTC

Retirement accounts (RRSP, RRIF, IRA, Roth, pensions)

• RRSP contributions as a US citizen in Canada
• RSP vs RRSP: are they the same thing?
• The spousal RRSP for US citizens in Canada
• RRIF conversion and minimum withdrawals for cross-border filers
• IRA and Roth IRA contributions for Americans in Canada
• Pension income splitting across the border
• The OAS clawback for non-residents
• Taking the commuted value of a Canadian pension before moving

Real estate

• Rental income across the border: the gross withholding trap
• A Canadian selling US real estate: FIRPTA and the US return
• A US citizen buying Canadian property: the foreign-buyer taxes
• Selling your home after crossing the border
• Mortgage interest across the border

Short-term rentals and Florida property

• A Canadian buying a US vacation rental: how to hold it
• Buying in Florida: hold it personally, in an LLC, a company, or a trust?
• A Canadian snowbird renting on Airbnb: the full tax picture
• A snowbird just bought a Florida condo: does that change my taxes?
• Renting a Florida condo on Airbnb: how it differs from a normal rental
• The 14-day rule for a Canadian's Florida condo
• Is 30% really taken off US rental income? Electing out
• Airbnb tax withholding for non-US property owners
• Does managing a US Airbnb make me a US tax resident?
• Reporting US Airbnb income on a Canadian return
• My US LLC is now on Airbnb: what changed for Canadian tax
• A Canadian selling a US rental: what is depreciation recapture?
• FIRPTA, cost segregation, and recapture on a vacation-rental sale
• Selling a cross-border short-term rental: the exit checklist
• US estate tax on a Canadian's Florida vacation rental
• Moving back to Canada but still own Florida: sell before I go?

Business and self-employment

• A Canadian starting a US business: entity choice and the LLC trap
• Starting a business in Canada as a US citizen or resident
• Incorporating across the border: corporation, C corp, LLC, or ULC
• When your Canadian corporation becomes a CFC: Form 5471 and GILTI
• Winding up a Canadian corporation after moving to the US
• The section 85 rollover across the border and section 367
• The section 199A QBI deduction for cross-border filers
• Self-employed across the border: freelancers and sole proprietors
• Transfer pricing between Canada and the US
• W-8BEN-E: what a Canadian corporation files to stop US withholding
• Royalties across the border: what the treaty exempts
• The cross-border digital nomad
• Employee or contractor across the border

Investments, gifts, and estates

• Capital gains tax in Canada and the US compared
• Dividends across the border: treaty withholding rates
• Interest across the border: why the treaty rate is zero
• Exchange rates on cross-border returns
• Gambling and lottery winnings across the border
• Gifts across the border: the US gift tax and Form 3520
• Inheriting across the border: deemed disposition and US estate tax
• Dying with assets in both countries: the executor's sequence
• Do you need two wills? Cross-border estate planning
• Donating across the border: Article XXI and its limits
• Spousal support across the border
• Income splitting across the border
• RESP withdrawals across the border

Employment, payroll, and benefits

• The cross-border business traveler
• Cross-border payroll: what an employer owes
• Remote work across the Canada-US border
• Form 8233: stopping US withholding on treaty-exempt wages
• Severance across the border
• Deferred compensation across the border: NQDC and 409A
• The home office across the border
• State income tax for cross-border workers
• Tax equalization for cross-border relocations
• EI benefits across the border
• Maternity and parental benefits across the border
• Disability benefits across the border: CPP-D, SSDI, and the DTC

Forms, deadlines, and compliance

• When a Canadian has to file a US tax return
• Form 1040-NR: the seven situations for a Canadian
• US filing deadlines for Americans in Canada
• Cross-border filing deadlines: the two calendars side by side
• Estimated taxes and instalments in both countries
• Year-end planning for cross-border filers: the checklist
• The FBAR in your first US year
• Joint accounts across the border: the FBAR and T1135
• Form 1042-S: getting back US tax withheld at 30%
• NR301: cutting Canadian withholding to the treaty rate
• Amending a cross-border return: 1040-X and T1-ADJ
• Late-filing penalties on both sides of the border
• Cross-border audits: what the CRA and IRS share
• Tax debt across the border: who can collect what
• Alternative minimum tax on both sides of the border
• What drives the cost of a cross-border tax return
• What a cross-border tax accountant actually does

Catching up: streamlined filing and delinquent returns

• What is the Streamlined Foreign Offshore Procedure, and do I qualify?
• SDOP vs SFOP: which streamlined track?
• The non-willfulness certification the IRS will accept
• Why streamlined submissions get rejected
• The streamlined 5% penalty: what is it 5% of?
• Haven't filed US taxes in years: how far back?
• Can I just start filing going forward instead of streamlined?
• Late on FBARs: just file them, or do I need streamlined?
• Unreported income was employment, not account income: still streamlined?
• Streamlined vs Voluntary Disclosure: when willfulness changes the calculus
• DIIRSP: the IRS procedure for late international information returns
• What happens after a streamlined filing? Audit risk
• State tax after a streamlined filing: what the IRS program doesn't cover
• RRSP, TFSA, and RESP in a streamlined filing
• Streamlined filing with PFICs and Canadian mutual funds
• Streamlined filing for married couples: both-spouse rules
• Streamlined filing for retirees with Canadian pensions
• Streamlined filing for the self-employed and business owners
• How cryptocurrency complicates a streamlined catch-up
• Streamlined filing for Canadian snowbirds who became US tax residents
• The green card holder in Canada using streamlined to catch up
• Streamlined filing for Americans abroad outside Canada
• Streamlined filing: the real cost for a Canadian

Penalties, relief, and audits

• CRA T1135 penalties and how to fix missed foreign-property reporting
• The CRA VDP cross-border: coordinating with IRS streamlined
• The FBAR penalties decision tree
• Form 3520 penalty abatement: what the policy change means
• Form 5471 and 5472 penalties: abatement after the Tax Court rulings
• Can I ask the CRA to cancel penalties and interest?
• Both countries auditing the same income: what happens, and who goes first
• Cross-border penalty coordination: owing penalties in both countries

Estates and trusts across the border

• Do bare trusts still have to file a T3? Where the rules stand now
• A deceased parent owed the CRA or IRS: what the estate and heirs owe
• Deemed disposition at death vs the US stepped-up basis
• Executor personal liability on a cross-border estate
• Form 706-NA: the US estate tax return for Canadians
• In-trust-for (ITF) accounts: the cross-border tax problems
• Joint tenancy (JTWROS): the cross-border tax traps
• The kiddie tax: US children of Canadian parents
• Life insurance across the border: the 4371 excise and section 7702
• RRSP and RRIF at death with a US-person beneficiary
• Spousal trusts for mixed-status couples across the border
• Testamentary trusts after 2016: the GRE and the QDT
• A US person as trustee: the Canadian trust residence risk
• A Canadian trust with a US beneficiary: the throwback tax and Form 3520
• The QDOT: the estate tax marital deduction for a non-citizen spouse
• Estate freezes, alter-ego and bypass trusts across the border

Moving to Canada: the American's first-year playbook

• Do I still file US taxes after moving to Canada?
• When do I become a Canadian tax resident after moving?
• Your first Canadian tax return after moving: the newcomer rules
• Your 401(k) after moving to Canada: options and tax
• Traditional IRA and Roth IRA when you move to Canada
• Keeping a US brokerage account after moving to Canada
• RRSP, TFSA, and FHSA for Americans in Canada: which accounts
• Moving to Canada with a US LLC: why it backfires
• Selling your US home after moving to Canada: the tax
• A US remote job while living in Canada: payroll and tax
• Arrival cost-basis step-up: the Canada-US mismatch
• Social Security and Medicare after moving to Canada
• 529 plans when the family moves to Canada
• Your HSA after moving to Canada
• Breaking US state residency when you move to Canada
• The T1135 newcomer first-year exemption

Leaving Canada: the departure playbook

• Do I pay departure tax when I leave Canada? What triggers it
• When do I stop being a Canadian tax resident?
• Your RRSP after moving to the US: keep, collapse, or draw down
• Your TFSA after moving to the US: close or keep
• Canadian investment accounts after moving to the US: the PFIC problem
• Selling your Canadian home after moving to the US: section 116
• Renting out your Canadian home after moving to the US: NR6 and section 216
• CPP and OAS after moving to the US: collecting and tax
• Your first US tax return after moving from Canada: dual status
• The deemed disposition at departure: what is exempt, and the forms
• Your Canadian corporation after moving to the US: CCPC to CFC
• Your RESP when the family moves to the US
• Does a TN visa make me a US tax resident?
• Deferring the departure tax: the security election (T1244)
• Stock options and RSUs when moving from Canada to the US
• The year you move: who taxes what, Canada and the US

Snowbirds and part-year cross-border life

• How many days can a snowbird spend in the US before tax problems start?
• Do snowbirds pay US tax on their Canadian income?
• Renting out US property as a Canadian: the 30% withholding and the net election
• Selling US property as a Canadian: FIRPTA withholding and the 8288-B
• How Canadians reduce US estate tax exposure on Florida property and US stocks
• What happens if I spend more than 183 days in the US?
• Working remotely from the US for the winter: when a laptop creates US tax
• US casino winnings as a Canadian: the 30% and the treaty refund
• Why every US bank and broker asks Canadians for a W-8BEN
• US dividend withholding for Canadian investors: the 15% and the credit
• The ITIN for Canadians: when you need one and how the W-7 works
• A Canadian sells US stocks: who taxes the gain?
• The six-month immigration rule vs the 183-day tax rule
• A US work assignment under 183 days: the treaty exemption
• A Canadian business selling into the US: the three nexus rules
• State taxes for snowbirds: the day-count rules the treaty doesn't bind

Cross-border families and life events

• Marrying a US citizen: what actually changes for a Canadian
• Filing jointly with a nonresident spouse: the 6013(g) election
• Divorce and support payments across the border
• A US person inheriting from Canada: Form 3520
• A Canadian inheriting from a US estate
• Canadian parents gifting money to US children
• US parents gifting to Canadian children: the gift tax
• A child born in the US to Canadian parents: tax and citizenship
• US citizenship through a parent: does your child have it?
• Tuition across the border: the TL11A and the 1098-T
• Claiming non-resident dependants across the border
• Pension income splitting when one spouse is a US person
• Estate planning with mixed-citizenship children
• Charitable giving across the border: which credits work
• Family loans across the border: the prescribed rate and the AFR
• Survivor benefits across the border: CPP and Social Security

Cross-border business owners and the self-employed

• The best US entity for a Canadian owner (LLC, LP, or C corp)
• Do I charge GST/HST to US clients?
• Salary versus dividends for a US-citizen CCPC owner
• A Canadian company hiring US contractors
• A US company hiring Canadian contractors
• Regulation 105: the 15% Canada withholds on services
• Should a US citizen in Canada incorporate?
• The unlimited liability company (ULC): cross-border uses
• Transfer pricing for small cross-border companies
• Expanding to the US: branch or subsidiary?
• A US business selling into Canada: GST/HST
• A Canadian Amazon FBA seller's US taxes
• Hiring a remote employee across the border
• Shareholder loans across the border (subsection 15(2))
• Selling your Canadian business to a US buyer
• Running a Canadian and a US company: when two entities are worth it

Fixing the past and dealing with the tax authorities

• An IRS audit while living in Canada: what expat audits look like
• A CRA review letter vs an audit: which one you got
• The CRA's Voluntary Disclosures Program, cross-border
• The IRS CP2000 notice with Canadian income
• Owing the IRS while living in Canada: payment options
• Owing the CRA while living in the US: payment arrangements
• How far back can the CRA and IRS reassess?
• A FATCA letter from your Canadian bank: what to do
• Passport revocation for tax debt
• IRS penalty relief: first-time abatement and reasonable cause
• CRA taxpayer relief: cancelling interest and penalties
• Double-taxed anyway: competent authority and the MAP
• Can the CRA and IRS collect each other's tax debts?
• Unfiled US returns as a Canadian resident: the catch-up
• Unfiled Canadian returns as a US resident: the catch-up
• Civil penalties vs criminal tax evasion, cross-border

Cross-border real estate, from purchase to sale

• A Canadian buying US property: the pre-closing tax checklist
• An American buying property in Canada: rules and taxes
• The Underused Housing Tax: who actually has to file
• Principal residence exemption vs the US section 121 exclusion
• Cross-border mortgages and interest deductibility
• The family cottage with cross-border heirs
• Pre-construction condos across the border: buyer taxes
• Short-term rentals (Airbnb) across the border: the taxes
• Does a 1031 exchange work for Canadian property?
• Land transfer taxes and closing costs: Canada vs the US
• Holding US real estate through a Canadian corporation
• Cross-border REIT investing and its taxes
• Property flipping rules in Canada and the US
• Converting a home to a rental: change-of-use across the border
• Florida property tax and homestead for Canadian owners
• How Americans should hold Canadian real estate

Streamlined edge cases, FATCA, and the US information returns

• Domestic or foreign streamlined? The residency test that decides your track
• The streamlined domestic 5% penalty: exactly what it is computed on
• The non-willfulness statement (Form 14653): what a credible narrative contains
• The ways a streamlined submission fails, and the fixes before you mail it
• After you file streamlined: what the IRS does with it
• Streamlined fixes the federal years only: the state returns it never touched
• Registered accounts inside a streamlined submission: RRSP, TFSA, RESP
• Streamlined or the IRS Voluntary Disclosure Practice: where willfulness moves you
• Unfiled US returns with only a salary: is streamlined still the route?
• Born dual, never left Canada: the US return you owe anyway
• Your Canadian bank closed your account over FATCA: why, and how to bank again
• FATCA for Canadians and Americans in Canada: what banks report, who should care
• Form 8938 and the FBAR side by side: thresholds, and why most file both
• Form 8833: the treaty positions that must be disclosed, and the penalty
• Form 3520-A: the trust files it, you file the substitute, the March 15 deadline
• Form 8891 is gone: how RRSP treaty deferral works now

Cross-border corporations, entities, and business moves

• Subpart F inside a Canadian corporation: passive income taxed immediately
• The section 962 election: corporate rates on a Canadian corporation's inclusion
• FAPI: why Canada taxes a US corporation's passive income before any dividend
• RDTOH when the shareholder files a 1040: Canada's refund does nothing for the US
• Form T1134 for a Canadian who owns a US corporation or LLC
• Your spouse owns the Canadian corporation: when Form 5471 attribution makes it yours
• Check-the-box on a Canadian corporation before moving to the US: only a ULC can
• GILTI has a new name: what the renamed regime changes for a Canadian corporation
• Owning US S corporation or partnership interests from Canada
• Kept your Canadian clients after moving to the US? Which country taxes the fees
• Structuring an E-2 business as a Canadian, an LLC, or a C corporation
• Moving to the US on an E-2 visa: departure, business entity, first-year returns
• Sell the Canadian business before you move or after? The exemption, the CFC rules, and the buyer
• Your GST/HST account after moving to the US: deregister, keep, or zero-rate
• Getting a US Employer Identification Number from Canada: SS-4 without an SSN
• Keeping your Canadian job after moving to the US: who withholds CPP and US payroll

Cross-border retirement accounts, pensions, and Social Security

• RRSP and 401(k) compared: contribution rules, treaty treatment, and what each becomes across the border
• TFSA and Roth IRA: look-alike accounts each country refuses to recognize
• Moving a 401(k) or IRA into an RRSP: the 60(j) rollover and the withholding that leaks
• The section 217 election: when filing a Canadian return beats accepting the 25%
• Getting 15% instead of 30% withheld on US retirement withdrawals from Canada
• The Windfall Elimination Provision is gone: what cross-border retirees with CPP get back
• Timing CPP and Social Security together: start ages, survivor math, and how the treaty taxes each
• Combining CPP and Social Security work credits: how the totalization agreement qualifies you
• Roth conversions before a move to Canada: why the window closes at the border
• The RDSP after a move to the US: grants stop, the IRS sees a trust
• Retiring to Canada from the US: the tax picture for Social Security, IRAs, Medicare, and the estate
• Retire in Canada or in the US? The tax comparison for dual citizens, account by account
• California and your retirement withdrawals after leaving: the federal law that stops source-state pension tax
• Part XIII withholding after you leave Canada: the 25% default and the treaty rates
• A Canadian inherits a US IRA or 401(k): the ten-year clock, the withholding, and the treaty rate
• The Net Investment Income Tax for Americans in Canada: the 3.8% no foreign tax credit offsets

Cross-border moves, life events, and foundations

• One spouse in the US, one still in Canada: residency and filing for each
• The Windsor-Detroit commuter: why daily crossings don't make you a US resident
• Canadian students on F-1 and OPT: the exempt-individual years and when the day count starts
• Returning to Canada after years in the US: the re-entry checklist
• Returning to Canada with property you still own: the election that unwinds your old departure tax
• Paid departure tax, then the asset fell: the loss-carryback election that refunds part of it
• Departure tax paid to Canada, gain taxed again in the US? The treaty election that resets your US basis
• ESPP shares after moving to Canada: the discount the US still taxes and the gain Canada measures from arrival
• The Canada Child Benefit on a US return: not taxable in Canada, reportable to the IRS?
• The US Child Tax Credit for families in Canada: why claiming the exclusion forfeits it
• Giving up a green card to move back to Canada: the eight-year rule and Form 8854
• Claiming Canadian citizenship through a parent or grandparent: what changes on your taxes
• Are Americans in Canada taxed twice? Almost never, and the machinery that stops it
• The Canada-US tax treaty in plain English: what it settles, article by article
• How much more tax do you really pay in Canada? Federal, provincial, and state rates compared at real incomes
• Crypto on a Canadian and a US return: disposition rules, cost base methods, staking income, and the reporting forms

Forms, filings, and first steps

• Authorizing someone to deal with the CRA and the IRS: Form 2848 and the CRA representative authorization
• Forms NR73 and NR74: whether to ask the CRA to rule on your residency
• Counting 330 days: how the physical presence test works, and which 12 months to pick
• Putting US income on a Canadian T1: which lines, which exchange rate, and how the foreign tax credit is claimed
• Reading an NR4 for your 1040: which box is income, which is withholding, and where each goes
• Investing in Canada as a US citizen without PFIC trouble
• Buying from a non-resident seller in Canada: the 25% you must hold back and the section 116 certificate
• Moving back to Canada with a Florida home: sell before the move or after?
• Wash sales and superficial losses: two loss-denial rules with different windows
• Inheriting from someone who renounced: the section 2801 tax on gifts and bequests from covered expatriates
• Selling a short-term rental you ran from across the border: recapture, withholding, and the order to do it in
• Before you hire a cross-border accountant: why a written position review first
• What TFSA reporting on a US return actually involves, and why quotes for it vary so much
• An American moving to Canada: the status options and the tax obligations that start on each
• The 2025 US tax law for Canadians with US income: what changed for withholding, estate exemptions, and snowbird returns

Cross-border business structures

• A Canadian buying a Florida business: the purchase structure, the E-2 visa, the entity, and the Canadian tax
• A Canadian company expanding to Florida: subsidiary or branch, permanent establishment, and the first US hire
• A Canadian employer with US employees: payroll registration, the remote worker in Florida, and the totalization certificate
• A Canadian resident owning a US LLC: the hybrid entity problem, the double tax, and the fixes
• A Canadian selling Florida real estate: FIRPTA withholding, Form 8288-B, and the Canadian return
• A Canadian snowbird running a US business: substantial presence, Form 8840, and effectively connected income
• A US citizen owning a Canadian corporation: Form 5471, GILTI, subpart F, and the section 962 election
• A Canadian contractor on U.S. job sites: the construction permanent establishment, state licensing, and withholding
• A Canadian corporation with U.S. investment income: the W-8BEN-E, limitation on benefits, and the CCPC portfolio
• A Canadian e-commerce seller in the U.S.: Amazon FBA inventory, the treaty's storage exception, and sales tax
• A Canadian family business with U.S. heirs: the estate freeze, CFC and PFIC traps, and the succession
• A Canadian professional corporation with U.S. clients: no permanent establishment, the W-8BEN-E, and U.S. workdays
• A Canadian trust with U.S. beneficiaries: Form 3520, the throwback tax, and accumulated income
• Cross-border bookkeeping: currency, two sets of rules, and books that satisfy the IRS and the CRA
• Cross-border intercompany loans: interest withholding, thin capitalization, the 163(j) limit, and section 17
• Cross-border management fees between related companies: transfer pricing, Part XIII, and Regulation 105
• A cross-border partnership with Canadian and U.S. partners: section 1446 withholding and Forms 8804 and 8805
• Cross-border retirement for business owners: the IPP, the RRSP, the cash balance plan, and the owner who moves
• Cross-border stock options and equity compensation: workday sourcing, the Canadian deduction, and the U.S. ISO
• Moving a business from Canada to Florida: the corporate departure tax, continuance, and the owner's emigration
• The owner moves to Florida and keeps the Canadian corporation: CFC rules, the lost small business rate, and dividends
• Quebec cross-border tax: the second provincial return, Revenu Québec, the QPP, and the Quebec foreign tax credit
• A U.S. company selling into Canada: GST/HST registration, Regulation 105 withholding, and the Canadian permanent establishment

Next step

Fairlight prepares cross-border tax returns for people who file in both Canada and the US, and the planning behind them. See cross-border pricing or book a call.