Cross-Border Tax Guidance with Accountants

Here's how we assist:

Determining Tax Residency in Canada and the U.S.

We analyze your residency status using factors like home location, family ties, work, and nationality. Partnering with accountants, we apply the Canada-U.S. Tax Treaty to resolve dual residency, avoid double taxation, and claim credits—essential for cross-border tax planning.

Principal Residence Exemption (PRE) Eligibility

For property sales, we evaluate PRE qualification under CRA rules (e.g., Folio S1-F3-C2), including habitation and ownership criteria. We assess U.S. intersections like IRC Section 121 gains exclusions. 

Cross-Border Tax Considerations for Canada-U.S. Real Estate

We guide on capital gains, withholding, and reporting for cross-border home ownership or sales, including Canadian deemed dispositions and U.S. FIRPTA (15% withholding). 

Transferring Assets Across the Canada-U.S. Border

For gifting, selling, or inheriting assets, we advise on tax-efficient methods like trusts or rollovers, adhering to Canadian attribution and U.S. gift/estate rules. 

Cross-Border RSU and Equity Compensation Tax Guidance

For RSUs or stock options from U.S. employers, we explain Canadian vesting income (ITA section 7) and U.S. rules (IRC Section 83), addressing sourcing, double taxation, and deferrals. 

Tax Planning Strategies for Canada-U.S. Cross-Border Needs

We create legal frameworks for PRE optimization, deferrals, and foreign credits, plus advice for U.S. business growth (e.g., entity setup like Delaware LLCs, CFC/GILTI compliance).  For Canadians expanding in the U.S., we counter pitfalls like transfer pricing. 

Representing You in Canadian Tax Disputes

For CRA disputes like PRE denials, we handle negotiations, objections, and Tax Court appeals, gathering evidence and invoking treaties.