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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)

Salary vs Dividends for a US Citizen Who Owns a Canadian Corporation: GILTI Rewrote the Answer

September 14, 2026

The classic Canadian owner-manager arithmetic — salary or dividends, roughly integrated either way — breaks when the owner files a 1040: GILTI taxes the corporation's retained profit currently, dividends lose their US character advantages, and salary becomes the mismatch-free channel. Here is the compensation math with the American overlay, and the mix that usually wins now.

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Cross-Border Tax (U.S.–Canada)

Selling Your Canadian Business to a US Buyer: Shares vs Assets, the Exemption Worth Fighting For, and the Cross-Border Terms That Move After-Tax Value

September 14, 2026

US acquirers change the deal's tax texture: they push for assets or step-up structures while your lifetime capital gains exemption wants a share sale; earnouts, escrows, and rollover equity each carry two-country treatment; and the closing mechanics add withholding questions. Here is the seller-side map for the exit that crosses the border.

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Cross-Border Tax (U.S.–Canada)

Selling Your Canadian Home After Moving to the US: the Principal Residence Exemption, Section 116, and the 25% the Buyer Holds Back

September 14, 2026

Sell before you leave and the principal residence exemption usually makes the gain tax-free with no process. Sell after, and you are a non-resident vendor: the exemption still covers your resident years, but section 116 clearance applies, the buyer withholds 25% until the CRA certificate arrives, and the US may tax its share. Here is the before/after comparison and the clearance process.

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Cross-Border Tax (U.S.–Canada)

Selling Your US House After Moving to Canada: the Two-Year Window, the Arrival Step-Up, and Which Country Taxes What

September 14, 2026

The US home you left behind can usually be sold with little or no tax in either country — if it sells within the right window. The section 121 exclusion runs on a two-of-five-year clock from when you moved out, and Canada only taxes gain accruing after your arrival, measured from the arrival-date value. Here is the timing math and the traps for renters-out and procrastinators.

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Cross-Border Tax (U.S.–Canada)

Selling US Property as a Canadian: FIRPTA's 15% Withholding, the 8288-B Reduction, and the Two-Country Gain

September 14, 2026

When a Canadian sells US real estate, the buyer must withhold 15% of the gross price under FIRPTA — a prepayment, not the tax. A withholding certificate can shrink it to the real liability, the 1040-NR settles the actual gain at capital gains rates, and Canada taxes the same sale with a credit. Here is the closing-table mechanics and the refund math.

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Cross-Border Tax (U.S.–Canada)

Shareholder Loans Across the Border: Canada's One-Year Rule, America's Imputed Interest, and the Owner Who Borrowed From the Wrong Side

September 14, 2026

Borrowing from your own corporation is routine planning domestically and a two-rulebook problem across the border: Canada's subsection 15(2) includes unrepaid shareholder loans in income with a one-year fuse, the US imputes interest and can find deemed dividends, and cross-border configurations add withholding and PUC angles. Here is the map for owners on either side.

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Cross-Border Tax (U.S.–Canada)

Should a US Citizen in Canada Incorporate? The Honest Decision Framework Now That GILTI Taxes the Deferral Away

September 14, 2026

For Canadian professionals, incorporation's case is deferral — earn at 12%, invest the difference, pay yourself later. For a US citizen, GILTI deletes the deferral and Form 5471 adds rent, so the classic advice inverts. Sometimes the corporation still wins: liability, partners, a genuine business. Here is the decision framework run honestly, factor by factor.

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Cross-Border Tax (U.S.–Canada)

Social Security and Medicare After Moving to Canada: Your Credits Survive, Your Checks Follow, and Only Canada Taxes Them

September 14, 2026

Moving to Canada does not forfeit Social Security — credits stay earned, benefits are payable to Canada, the totalization agreement fills qualification gaps, and the treaty hands taxation of the benefit exclusively to Canada, which exempts 15% of it. Medicare is the opposite story: it does not travel. Here is how the retirement-benefits picture reassembles north of the border.

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Cross-Border Tax (U.S.–Canada)

State Taxes for Snowbirds: the Treaty Does Not Bind the States, and a Few of Them Count Your Days Too

September 14, 2026

The federal side of snowbird life is settled by the 8840 and the treaty — but states run their own residency and source rules, and neither instrument binds them. Florida, Arizona, and Texas ask nothing; California and New York can, if a snowbird's pattern meets their tests or their income touches their soil. Here is where state exposure actually comes from and how the classic destinations compare.

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Cross-Border Tax (U.S.–Canada)

Stock Options and RSUs When You Move From Canada to the US: Sourced by Where You Worked, Not Where You Exercise

September 14, 2026

Equity compensation ignores the departure tax and follows its own rule: the benefit is divided between the countries by where the work was performed between grant and vest, whenever exercise or vesting happens. Move mid-vest and every award becomes a two-country event with withholding in both. Here is the sourcing math for options and RSUs, and the moves worth making before the date.

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Cross-Border Tax (U.S.–Canada)

Do Newcomers File the T1135? Not in Year One — Here Is the Exemption, the Clock, and What Counts After That

September 14, 2026

Form T1135 — Canada's foreign property disclosure — exempts individuals for the year they first become resident. From year two, anyone whose foreign property cost exceeds C$100,000 files annually, and for arriving Americans nearly everything left behind counts: brokerage accounts, US bank accounts, rented-out real estate. Here is the newcomer rule, what is in and out, and the penalty structure that makes the form worth respecting.

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Cross-Border Tax (U.S.–Canada)

Traditional and Roth IRAs After Moving to Canada: the Treaty Election, the Canadian Contribution Trap, and How Each Is Taxed

September 14, 2026

Both IRA types survive a move to Canada, but they behave differently: the traditional IRA defers automatically like a pension, while the Roth keeps its tax-free character only if a one-time treaty election is filed — and loses it partially forever if you contribute a single dollar after becoming Canadian-resident. Here is the rulebook for each.

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Cross-Border Tax (U.S.–Canada)

Transfer Pricing for Small Cross-Border Companies: the Arm's Length Rule, the T106 and 5472 Forms, and the File That Keeps Both Sides Calm

September 14, 2026

The moment your Canadian company and your US company transact with each other — services, goods, loans, a shared owner's time — both countries require arm's length pricing and annual disclosure: Canada's T106, America's 5472, and contemporaneous documentation behind the numbers. Here is transfer pricing scaled to companies with two entities and one owner.

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Cross-Border Tax (U.S.–Canada)

Running a Canadian Company and a US Company: When the Two-Entity Structure Is Worth It, How Money Moves Between Them, and the Annual File That Keeps It Legal

September 14, 2026

At some point the cross-border business asks whether one corporation is still enough — and the two-company answer brings real benefits (liability walls, commercial fit, clean payroll) at the price of a permanent intercompany discipline: transfer pricing, twin information returns, and deliberate repatriation. Here is when to build the pair, how to run it, and how money actually comes home.

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Cross-Border Tax (U.S.–Canada)

A US Work Assignment Under 183 Days: When the Treaty Keeps a Canadian Employee Out of the US Tax System Entirely

September 14, 2026

Article XV of the treaty exempts a Canadian resident's pay for US workdays if the pay stays under US$10,000 — or if US presence stays under 183 days in any twelve-month period and no US employer or US permanent establishment bears the cost. Get the three conditions right and a secondment produces no US return at all; miss one and payroll splits across the border. Here is the test and its traps.

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Cross-Border Tax (U.S.–Canada)

The Unlimited Liability Company: the Canadian Hybrid US Planners Love, the Treaty Trap Inside It, and Where a ULC Still Earns Its Keep

September 14, 2026

The ULC — a Canadian corporation the US can treat as a flow-through — was the darling of cross-border structuring until the treaty's anti-hybrid rule stripped withholding relief from its classic dividend flows. It survives in narrower roles: US buyers acquiring Canadian targets, check-the-box planning, and structures engineered around the trap. Here is what a ULC is, where Article IV(7) bites, and the workarounds that keep the useful cases alive.

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Cross-Border Tax (U.S.–Canada)

A US Business Selling Into Canada: When GST/HST Registration Hits You, the Simplified vs Normal Regimes, and the Import Mechanics

September 14, 2026

Canada's sales tax reaches non-resident vendors deliberately: digital products and services to Canadian consumers, marketplace and warehouse sales, and conventional selling with Canadian presence each trigger registration under distinct regimes. Add import GST at the border and provincial taxes on top. Here is the US seller's Canadian map.

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Cross-Border Tax (U.S.–Canada)

US Casino Winnings as a Canadian: the 30% Taken at the Cage, and the Treaty Refund Most Players Never Claim

September 14, 2026

Win big in Vegas and the casino withholds 30% before you leave the floor — but the Canada-US treaty lets Canadians deduct their US gambling losses against those winnings and reclaim tax on the difference, via an ITIN and a 1040-NR. Here is which games withhold, how the refund math works, and the records that make it claimable.

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Cross-Border Tax (U.S.–Canada)

US Citizenship Through a Parent: Does Your Canada-Born Child Already Have It — and What Follows If They Do

September 14, 2026

A child born in Canada to a US-citizen parent may be a US citizen automatically — if the American parent lived in the US long enough before the birth. The transmission rules decide by physical-presence arithmetic, and the answer determines whether the child has lifelong US filing obligations or a choice their parents can make. Here is the test, and what each answer means.

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Cross-Border Tax (U.S.–Canada)

A US Company Hiring Canadian Contractors: the W-8BEN Instead of the 1099, and Why Remote Work in Canada Means No US Withholding

September 14, 2026

When an American company pays a Canadian contractor who works from Canada, the compensation is foreign-source income of a foreign person — no US withholding, no 1099, just a W-8BEN (or W-8BEN-E) in the vendor file proving why. The exceptions track where the work happens and what the payment really is. Here is the US payer's map, and the Canadian contractor's own side of it.

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Cross-Border Tax (U.S.–Canada)

US Dividend Withholding for Canadian Investors: Why 15% Comes Off the Top, Where It Doesn't, and How the Credit Comes Back

September 14, 2026

Every US dividend a Canadian earns arrives 15% lighter — the treaty rate collected at source — and Canada then taxes the full dividend with a credit for the withholding. But the rate, the credit, and even whether withholding applies at all depend on the account it sits in: taxable, RRSP, or TFSA give three different answers. Here is the map, account by account.

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Cross-Border Tax (U.S.–Canada)

US Parents Gifting to Canadian Children: the Gift Tax Belongs to the Giver — Annual Exclusions, Form 709, and the Canadian Side's Silence

September 14, 2026

When an American parent gives to a Canadian child, the US gift tax rules follow the parent: annual exclusions per child, the lifetime exemption above them, Form 709 to track it — while Canada asks the recipient nothing at all. Here is how the giving side works, what the Canadian child reports (almost nothing), and the property choices that keep it clean.

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