News and Insights

Cross Border and US Taxation

February 10, 2025

Sector:

The current political climate has driven an increase in clients moving from Canada to the US, or in some cases, the opposite.  Many clients are not aware of their tax obligations.  At the very least, many clients are not aware that they could have both their US and Canadian taxes done within the same firm. 

Additionally, we have seen an increase in activity from the US Internal Revenue Services (IRS) in pursuing compliance of tax filings related to foreign corporations and American citizens living in Canada. In some cases, the fines and penalties imposed by the IRS can be significant. 

What cross-border and US tax services does Kreston GTA provide? 

We have specialized accounting and tax services designed to help individuals, businesses, and organizations navigate the complexities of tax laws and regulations that apply across both countries. We employ Canadian and US CPAs and work with our partners within the Kreston Global network around the world. 

For Individuals 

Personal Tax Planning and Compliance: 
Preparation and filing of personal income tax returns in both the US (IRS) and Canada (CRA). 
Assistance with dual residency filing positions. 
Reporting and compliance with foreign bank account reporting (FBAR/FINCEN) and the IRS Form 8938 (FATCA). 

Expatriate Tax Services: 
Guidance on the US’s worldwide income taxation for citizens and green card holders living in Canada and for Canadian residents working in the US. 
Utilizing the US-Canada Tax Treaty to minimize double taxation and claim treaty benefits 
Preparation of departure/exit tax. 

Retirement and Estate Tax Planning: 
Cross-border planning for pensions, IRAs, RRSPs, and other retirement accounts; and planning for estate and inheritance tax implications across borders. 

For Businesses

Corporate Tax Compliance:
Filing corporate income tax returns in the US and Canada for businesses with cross-border operations.
Compliance with sales tax (Canada GST/HST, US state/local taxes).

Transfer Pricing and Intercompany Transactions:
Documentation and compliance with transfer pricing rules for cross-border transactions between related entities. 

Permanent Establishment Guidance:
Assessment of whether a business creates a taxable presence (permanent establishment) in the other country.

Cross-Border Payroll Services:
Withholding tax compliance for employees working across borders.
Employer obligations for social security (US FICA/Medicare vs. Canadian CPP/EI).

Tax Structuring and Planning:
Advice on the most tax-efficient ways to structure cross-border operations; mergers, acquisitions, or investments across borders.
International structuring to maximize research and development tax credits.

Other Related Services:
Voluntary Disclosure Programs: Assistance with disclosing unreported income or assets to avoid penalties.
Audit and Representation: Representing clients during audits by the IRS or CRA.
Tax Dispute Resolution: Resolving cross-border tax disputes and appeals.

Our Cross-Border Taxation team has the experience and knowledge to tackle a range of challenges. And, if they don’t have the answer, they’ll call in an expert to make sure you get one.