Tax guides
Personal tax under rules on both sides of the border and the Canada–US tax treaty.
Americans resident in Canada generally file two returns every year: a Canadian return on worldwide income and a US return on the same income. Foreign tax credits prevent most double tax: Canada taxes Canadian income first, and the US credits that tax or excludes earned income up to a limit. Reporting forms such as the FBAR come on top.
Individuals · Self-employed
The US taxes income in Canada's registered accounts unless the treaty or US rules say otherwise. RRSP and RRIF income is deferred until withdrawal, usually automatically, with no Form 3520. TFSA income is generally taxable each year. No binding IRS guidance says how TFSAs, FHSAs, RESPs or RDSPs are taxed. All generally count toward the FBAR and Form 8938.
Individuals
A Canadian resident selling personally owned US real estate is generally subject to FIRPTA withholding on the gross sale price. File Form 1040-NR to calculate the final US tax and claim excess withholding back. Report the gain in Canadian dollars on your Canadian return, and consider a foreign tax credit for final US tax. State filings may also apply.
Individuals
A Canadian tax resident who directly owns a US rental generally reports its rent and allowable expenses in Canadian dollars with their T1, usually using Form T776. In the US, gross rent generally faces 30% tax unless you elect net-income treatment and file Form 1040-NR. State and local rental taxes depend on the property's location.
Individuals
If your failure was not willful and you meet the non-residency test, the main IRS option is the Streamlined Foreign Offshore Procedures: file the last 3 years of US returns and 6 years of FBARs, sign Form 14653, and pay tax and interest. Done right, the usual penalties are waived unless an audit finds fraud or a willful FBAR violation.
Individuals · Self-employed
A move may require a Canadian departure return. If you first become a US tax resident in the move year, US worldwide-income reporting generally starts on your residency date; US citizens generally report worldwide income for the full year. Set both residency dates, then check departure tax, treaty rules for investments and your home, registered accounts, and pensions before filing or selling.
Individuals
Canada generally taxes your worldwide income from the date you establish residential ties there. US citizens and continuing green card holders generally still file US returns; other movers may have a final US resident or dual-status return. Record property values on arrival, check state residency, and review retirement accounts and a US home before moving.
Individuals
First, the executor gathers authority papers and worldwide values. File Form 706-NA within nine months if required, even when treaty relief removes tax; the estate pays any US estate tax. Request an IRS transfer certificate when needed, file Canadian and US income returns, and obtain CRA clearance before distributing, plus Quebec clearance where applicable. US heirs check separate reporting.
Individuals
Yes, if your days meet the US substantial presence test: at least 31 days this year and 183 weighted days over three years. A Canadian who meets it may still be a nonresident by filing Form 8840 on time (under 183 days this year, closer ties to Canada) or, for income tax only, by claiming Canadian residence under the treaty.
Individuals
A move does not erase tax on earlier work. The former country may tax part of a later RSU vest, option, bonus or final pay; your new country of residence may tax it too. Check the award's service period, file the required returns, recover excess withholding from the country that took it, and claim any credit for eligible final tax.
Individuals
Canada does not automatically shelter a US HSA or 529 plan. The owner or a trust may owe Canadian tax on annual earnings or a withdrawal; a resident contributor or beneficiary can also owe a deemed resident trust's tax. First confirm residence, including any treaty tie-breaker, and account ownership. Do not cash out solely because you are moving.
Individuals
Canada generally waits to tax a traditional IRA or employer 401(k) until you receive a taxable payment. A Roth IRA needs a Canadian treaty election to protect its growth, and contributions after you become resident can end that protection for later growth. Some lump sums qualify for an RRSP deduction, but US withholding and early withdrawal tax can still apply.
Individuals
You can file both returns yourself if you can establish where you are tax resident, identify every required return, and reconcile income and foreign tax credits across countries. Get cross-border help when residence changes, treaty claims, elections, business income, or mismatched tax years make one return depend on the other. Paper filing alone does not require an accountant.
Individuals · Self-employed
If you live in Canada and work remotely from Canada for a US employer, Canada generally taxes your pay and the US generally does not tax those workdays if you are not a US citizen or tax resident. Workdays in the US can be taxed there too. Report all pay in Canada; a US return may be needed for US work or a refund.
Individuals
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