Residency & Status

Residency is a question of fact, not of citizenship or visa. These guides explain the tests each country applies, how ties are weighed when the facts point both ways, what changes on the day you arrive or leave, and why a residency certificate from one country is evidence rather than proof for the other.

Residency & Status — 3 in-depth guides

2026-07-22

Do Dual Citizens Pay Taxes in Both Countries

Do dual citizens pay taxes in both countries. How it actually works, what the relief requires, and the mistakes that cost the most — answered properly rather than guessed.

2026-07-06

Do I Have to Report Dual Citizenship

A practitioner's guide to do I have to report dual citizenship: the rule that decides it, the claims that make it real, and the quick answers to every version of the question.

2026-05-08

Do Green Card Holders Living Abroad Have to File Taxes

Do green card holders living abroad have to file taxes. How it actually works, what the relief requires, and the mistakes that cost the most — answered properly rather than guessed.

Other topics NRI & India, Foreign Income Basics, Tax Treaties, Estates, Gifts & Trusts, Working Across Borders.

← All cross-border tax guides

Cross-border situations we are engaged for

Case study 1

Work-visa holder's tax residence determined apart from immigration status

A Canadian working in the United States on a work visa needed their tax residence determined separately from their immigration status before either return was prepared for the year. We reviewed the residence tests independently of the visa itself and confirmed the position each return needed to reflect.

Case study 2

Infant emigrant's continuing US filing obligation and open years established

A person who left the United States as an infant and had never filed discovered the citizenship-based filing obligation had continued the entire time and needed the open years established. We reviewed the client's history, confirmed which years remained open, and set out the filing that would bring the position current.

Case study 3

Cross-border trust's filing duties assigned before it was settled

A family settling a trust with members in two countries needed to determine upfront who among the trust, the settlor and the beneficiary carried which filing duty. We reviewed the proposed structure and assigned each party's obligation before the trust was actually settled.

Case study 4

A Canadian Working in the US on a Work Visa

Immigration status and tax residence are different tests, and a visa says nothing about which country taxes the salary. The file fixes residence, applies the employment article, and sequences the two returns so the credit lands where it is usable.

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Case study 5

Never Filed a US Return — and Only Just Found Out

Born in the United States, left as an infant, and told by a bank that the returns were owed all along. The work is sequencing: establish which years are actually open, choose the catch-up route on the facts rather than filing quietly, and claim the exclusions and credits that were never taken.

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Case study 6

A Family Trust Abroad With Reporting on Both Sides

A trust settled in one country and a beneficiary living in another produces reporting for the trust, the settlor and the beneficiary, on different forms and different dates. The engagement maps who files what before anything is prepared.

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Case study 7

A US LLC Owned From Canada

The two countries classify the vehicle differently, so relief that ought to apply frequently does not and the same profit can be taxed in both hands. The engagement examines whether the structure can be changed and what the change itself costs.

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Case study 8

A 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.

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All case studies — every published engagement in one place.

Core International & Cross-Border Tax Services

International Tax Planning & Advisory

Strategy and compliance for income, assets and families spread across borders.

One coordinating team: filings on every side of the border are sequenced so treaty relief and foreign tax credits are claimed once — and in the right country.
U.S. & Cross-Border Tax Returns
Dual filers: U.S. citizens in Canada and Canadians with U.S. income run two parallel systems — we prepare both, in the right order, every year.
Expat & Emigration Tax
The move year is its own project: the elections and valuations filed that year decide the next decade of both countries’ returns.
Non-Resident Canadian Tax
Default withholding is 25% of gross: elective returns routinely turn over-withheld rent and pensions into refunds.
Transfer Pricing & BEPS
Documentation prepared with the return is the cheapest insurance in international tax; reconstructing it during an audit is the most expensive.
Cross-Border Estates & Trusts
Wills drafted for one country routinely misfire in the other — deemed disposition here, estate tax there, credits in between.
Cross-Border Corporate Tax
Expansion raises the same four questions every time — entity, PE, repatriation, payroll. We answer them before the tax authorities do.
India Tax for NRIs & Returning Residents
The deduction is taken on the sale price, not the gain — which is why an NRI property sale strands cash unless the certificate is applied for before closing.
Canadian Tax with a Foreign Element
Residency is decided on facts, not on a form — and the year you arrive or leave is the one where the largest amounts turn on the smallest details.
UAE Tax for Expats & Their Home Country
A zero-tax country is only half the answer — the question that decides the bill is whether the country you came from still treats you as resident.

Industries & Client Types We Serve Worldwide

Global E-commerce & Marketplaces
Technology & SaaS
Professional Services Firms
Cross-Border Real Estate
Importers, Exporters & Manufacturers
Athletes, Artists & Entertainers
Remote Workers & Digital Nomads
Investment Funds & Holding Companies
Global E-commerce & Marketplaces

Cross-border tax for sellers shipping worldwide: marketplace withholding, foreign registrations and inventory nexus handled before they become audits.

Marketplaces withhold, remit and report in their own right, so the tax position of a single sale is decided by where the stock sat, where the buyer was and which platform collected — not by where the company is registered. We reconcile the platform's own filings against the returns before either is submitted.

  • Foreign VAT / GST / sales tax registrations
  • Marketplace withholding reviews
  • Inventory nexus & PE analysis
  • Multi-currency books reconciled
Explore E-commerce & Marketplaces
Technology & SaaS
  • Cross-border revenue sourcing & withholding
  • IP structuring with real substance
  • Equity for cross-border teams
  • U.S. expansion: entity & PE setup
Explore Technology & SaaS
Importers, Exporters & Manufacturers
  • Transfer pricing documentation (s.247)
  • Customs value vs transfer price
  • Foreign affiliate reporting (T1134)
  • Country-by-country reporting
Explore Trade & Manufacturing
Athletes, Artists & Entertainers
  • Reg 105 & U.S. CWA agreements
  • Multi-state & country calendars
  • Touring income allocation
  • Royalty & image-rights withholding
Explore Athletes & Entertainers
Remote Workers & Digital Nomads
  • Residency analysis before moving
  • Employer payroll exposure
  • Totalization & social security
  • Foreign tax credits
Explore Remote Workers
Investment Funds & Holding Companies
  • Treaty access & PPT reviews
  • FAPI & surplus computations
  • Withholding-efficient routing
  • Governance & substance
Explore Funds & Holdcos

Our practitioners are alumni of leading accounting and tax institutions

Where our partners studied — CPA Canada (In-Depth Tax Program), AICPA, the Institute of Chartered Accountants of India and the Malaysian Institute of Accountants.

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