The most travelled corridor this practice works in. These guides deal with the specific pairing of Canadian and United States rules: the treaty articles that matter most, the retirement accounts each side recognises, the property rules for owners on the wrong side of the border, and the filings that come in pairs.
Canada–US Corridor — 1 in-depth guide
How Are US Dividends Taxed in Canada
A practitioner's guide to how are US dividends taxed in Canada: the rule that decides it, the claims that make it real, and the quick answers to every version of the question.
Other topics Cross-Border Basics, Business & Structure, Retirement & Pensions, Tax Treaties, Foreign Asset Reporting.
What these engagements turn on
First US hire's employer obligations identified before the assignment began
A Canadian company sending its first employee to work in the United States needed the resulting state and federal employer obligations identified before the assignment actually began. We reviewed where the employee would work and confirmed the registration and withholding duties the company would carry once the assignment started.
US contractor payments reviewed for correct withholding before the first payment
A Canadian business owner paying a US-based contractor needed the correct withholding and reporting position confirmed before the first payment under the new arrangement was made. We reviewed the contractor's status and confirmed the position before any payment went out under the arrangement.
Non-resident spouse election modelled against the alternative before filing
A Canadian resident married to a non-resident spouse needed the election to include that spouse on a US return modelled against the alternative before either return was actually filed. We built both scenarios and set out which position produced the better outcome for the household before the election was made.
A Canadian Employer With Staff in the United States
Employing someone in the US creates federal and state obligations that begin with registration, not with the first return. Which states are engaged is decided by where the work happens rather than where the company is.
Read how this one runsA Disclosure Where the Facts Were Not Innocent
Where non-compliance was not inadvertent, the certification-based routes are unavailable and a different practice applies, with its own protections and its own price. Establishing which side of that line the facts fall on is done before contact is made.
Read how this one runsA US Filer Married to Someone Outside the System
Electing to treat a non-resident spouse as a US filer buys joint rates and brings that spouse's worldwide income and foreign accounts into the return. The election is easy to make and hard to revoke, so both positions are modelled first.
Read how this one runsFifteen Per Cent Held Back From a Fee for Services in Canada
A payer must withhold from fees paid to a non-resident for services rendered in Canada, whether or not any tax is ultimately owed. A waiver applied for before the work is invoiced avoids the withholding; after it, the money comes back through a return.
Read how this one runsPutting a Foreign Hire on a Canadian Payroll
The obligation sits on the payer, and the payer is liable for what it failed to withhold. Registration, the residence question and any treaty exemption are settled before the first pay run rather than after.
Read how this one runsAll case studies — every published engagement in one place.
Core International & Cross-Border Tax Services
Strategy and compliance for income, assets and families spread across borders.
Industries & Client Types We Serve Worldwide
- Foreign VAT / GST / sales tax registrations
- Marketplace withholding reviews
- Inventory nexus & PE analysis
- Multi-currency books reconciled
- Cross-border revenue sourcing & withholding
- IP structuring with real substance
- Equity for cross-border teams
- U.S. expansion: entity & PE setup
- Reg 105 / 102 waivers
- Permanent establishment risk
- Partner mobility planning
- Cross-border withholding recovery
- Section 216 rental returns
- FIRPTA withholding recovery
- Section 116 clearance
- Treaty credit optimization
- Transfer pricing documentation (s.247)
- Customs value vs transfer price
- Foreign affiliate reporting (T1134)
- Country-by-country reporting
- Reg 105 & U.S. CWA agreements
- Multi-state & country calendars
- Touring income allocation
- Royalty & image-rights withholding
- Residency analysis before moving
- Employer payroll exposure
- Totalization & social security
- Foreign tax credits
Holding structures live or die on treaty access, beneficial ownership and substance — the MLI's principal-purpose test now sits over every arrangement.
A holding structure is only as good as its reporting. Foreign affiliates, accrued passive income and distributions each carry their own return, and the penalties on those attach to the form rather than to any tax being owed — so a structure that saves tax can still cost money if the information returns are late.
- Treaty access & PPT reviews
- FAPI & surplus computations
- Withholding-efficient routing
- Governance & substance
