I start a TN job in Texas next month — what do I do first?
Fix the dates before anything else. The day you begin work in the US, the day your family follows, and the day you give up the Canadian home each drive a different part of the answer, and they are rarely the same date. Once the dates are settled we work out which country taxes which part of the salary, because the treaty allocates employment income by where the work is performed rather than by who pays you. The US position is prepared first, since the Canadian return needs the final US figure to compute relief for the tax already paid there. The state comes last, and it is a separate question entirely.
Do I have to tell the CRA that I am working in the US?
There is no notification form for taking a job abroad. What changes is your Canadian residence position, and that is settled by facts rather than by an announcement. Where you keep a home, where your spouse and children live, and what you retain here all weigh. Many people on a US work visa stay Canadian residents for tax and keep filing a full Canadian return with relief for the US tax; others break residence on a datable day and file for part of the year only. The distinction decides whether Canada taxes your worldwide income for the whole year, so it is the first thing to document, not the last.
Which state taxes me if I live in one and work in another?
Both may. A state sets its own residency test and its own rules for sourcing income to work performed inside its borders, and it is not bound by the federal treaty between Canada and the US. So a position that works perfectly at the federal level can still leave you filing in two states, one taxing you as a resident on everything and the other taxing the days worked there. Relief between the two, where it exists at all, comes from their own credit rules. Treat the state as its own piece of work with its own evidence: where you slept, where you worked, and what the employer reported.
Do I keep paying into CPP or does US social security take over?
Social security sits outside the tax treaty. A separate totalization agreement decides which country's system a given period of work belongs to, so the same earnings are not charged twice, and evidence of that assignment is what an employer needs before it stops one set of contributions. The answer turns on whether you have been sent by a Canadian employer for a limited period or hired locally by a US one. It is worth settling early, because contributions are corrected through payroll rather than on a tax return, and a year of contributions to the wrong system is tedious to unwind after the fact.
What records should I gather before the first cross-border filing?
A calendar of working days by country for the year, your visa and entry dates, every payslip and year-end statement from the US employer, anything the Canadian employer issued before the move, and the state withholding shown on your pay. The day count matters because the allocation of salary between the two countries follows where the work was done, and a diary reconstructed a year later is much weaker than one kept as you go. Bring the employer's relocation policy too. Allowances, a housing benefit or an amount tied to staying put are each treated differently, and the policy document usually says what the payslip does not.
My US employer withheld nothing for Canada — is that a problem?
It is normal, and it is not the same thing as owing nothing. Withholding is a collection mechanism in one country; liability is decided separately in each. If you remain a Canadian resident, Canada taxes the salary and gives credit for the US tax on the part the treaty allocates there, and the shortfall becomes payable with the return or through instalments during the year. The uncomfortable version is a first year where a full Canadian liability arrives with no Canadian withholding behind it. Working the expected shortfall out early lets you set money aside instead of meeting it as a surprise.
Do dual citizens have to file US taxes if they live abroad?
Yes. US filing follows citizenship, not residence or where the income arose, and the obligation continues for as long as the citizenship does. Two further obligations travel with it and are keyed to account balances rather than income, so they can apply in a year with no US tax at all: the foreign bank account report to FinCEN, and the specified foreign asset statement with the return. Most people who discover a problem discover it there. See two returns as a dual citizen.
Am I a US tax resident if I live overseas?
If you are a US citizen or a green card holder, yes — the United States taxes on status, not location, and living abroad changes the reliefs available rather than the obligation to file. If you are neither, residence turns on the substantial presence test, a weighted day count over three years, with exceptions for certain visa categories and a closer-connection claim available in some circumstances. The two paths lead to completely different returns. See filing US taxes from abroad.
