Tax year 2025 (filed in 2026)
Pioneer Professional Accountants Inc. | Cross-Border Canada-US Tax
Updated: January 20, 2026
Cross-border tax planning is about reducing surprises, avoiding double taxation, and staying compliant in both countries. This planning checklist is designed for individuals with Canada-U.S. connections (moves, workdays, investments, or treaty claims).
1) Start with residency - do not assume based on immigration
·
U.S. tax residency is generally determined under
the green card test and the substantial presence test.
·
Canada residency is generally based on
residential ties and factual residency.
· Treaty tie-breaker rules may apply if both countries consider you resident in the same year.
2) Map your income to the correct country and year
·
Employment income (including bonuses/equity):
confirm source rules and workday allocation if you worked in both countries.
·
Investment income: organize
interest/dividends/capital gains by account and country.
· Pensions and retirement accounts: confirm treaty articles and withholding slips (e.g., 1099-R, NR4).
3) Use relief mechanisms to avoid double taxation
Foreign tax credits (FTC)
Foreign tax credits can reduce double taxation, but the credit is generally limited to tax attributable to the foreign-source income. Good documentation (withholding and proof of payment) is critical.
Treaty positions
If you take a treaty position that changes how the Internal Revenue Code applies, you may need Form 8833 unless an exception applies.
4) Foreign reporting - build a compliance checklist
·
FBAR (FinCEN Form 114) is filed separately from
your income tax return when required.
·
Form 8938 may apply for certain U.S. taxpayers
with specified foreign financial assets.
· Canadian reporting (e.g., T1135) may apply for certain Canadian residents with foreign property.
5) Practical planning tips
·
Track travel days (and keep support). It can
materially impact U.S. residency and sourcing for employment income.
·
Coordinate FX methodology across returns
(transaction-date vs average rates) and document your approach.
· Consider estimated tax planning where withholding will not cover the liability (U.S. and/or Canada).
Document checklist (typical)
·
Canada: T4/T4A, T5/T3, RRSP slips/receipts,
Canadian brokerage statements, rental summaries.
·
U.S.: W-2, 1042-S, 1099 series, brokerage
statements, 1099-R, state withholding details.
· Residency support: move dates, visas/immigration documents, and day-count/travel summary where relevant.
Important note
This guide is general information only. Cross-border filing positions are fact-specific and should be reviewed by a qualified advisor.
References
·
IRS: Claiming tax treaty benefits (Form 8833
rules and exceptions).
·
IRS Publication 519, U.S. Tax Guide for Aliens
(residency and nonresident filing guidance).
