Cross-border tax terms — F

39 terms beginning with F, each defined at mechanism level.

  • 15+Years of cross-border experience
  • 18,000+Clients served
  • 5.0Google rating
  • 4Global offices — India, USA, Canada & UAE
  • Fixed fee agreed before work starts
  • Offices in India, the USA, Canada and the UAE
  • 24-hour helpline: +1 (416) 619-0068

The definitions here are unnumbered on purpose. A concept survives a budget; a threshold does not, and the two are easy to confuse once they sit in the same sentence.

Cross-border vocabulary is mostly a record of disagreement. Two countries look at one arrangement and classify it differently, and the gap between the classifications is where the double tax, or the unintended relief, actually lives. Every entry closes with the filings it touches, because a definition you cannot attach to a form is not yet useful.

Knowing the term is the first half. Knowing whether it applies to your year, and what evidence proves it, is the half that changes the outcome. Every page here carries the name of the person who reviewed it and the date they did.

  • Factual resident — Someone resident in Canada because their ties are here in fact: a home available for their use, a spouse or dependants in Canada, and the economic and social connections that go with living somewhere.
  • FDAP income — Fixed, determinable, annual or periodical US-source income — dividends, interest, rents, royalties — taxed on a gross basis by withholding at source.
  • Foreign earned income — Wages and self-employment income for services performed outside the country.
  • Foreign earned income exclusion — The US election that removes foreign earned income from taxable income, up to an annually adjusted cap, for a filer whose tax home is abroad and who meets one of two qualifying tests.
  • Foreign housing exclusion — An additional US exclusion for housing costs abroad above a base amount, available alongside the earned income exclusion and computed by reference to it.
  • Foreign tax credit — A credit for income tax paid to another country against the domestic tax on the same income.
  • FTC basket — A category into which foreign income and foreign tax are grouped for credit purposes.
  • Functional currency — The currency in which an entity or branch actually operates, and the basis on which its results are translated for a foreign return.
  • FBAR — The report of foreign bank and financial accounts filed with the US financial-crimes bureau.
  • FinCEN 114 — The form number of the FBAR.
  • FATCA — The US regime requiring reporting of foreign financial assets by taxpayers and of US accounts by foreign institutions, backed by withholding.
  • Form 8938 threshold — The FATCA reporting threshold, which varies with filing status and with whether the filer lives in the United States or abroad — and is tested on two measures, not one.
  • Foreign affiliate — A non-resident corporation in which a Canadian resident holds a specified level of interest, bringing surplus computations and information reporting with it.
  • FAPI — Foreign accrual property income — passive income of a controlled foreign affiliate, attributed to the Canadian shareholder before any distribution.
  • FDII — Foreign-derived intangible income — a US deduction for income a US corporation earns from serving foreign markets.
  • Form 67 — The Indian statement of foreign income and foreign tax that supports a foreign tax credit claim, complicated by India's fiscal year not matching most others.
  • Form 10F — India's treaty information declaration, filed electronically to fill the gaps in a foreign residency certificate — which means a non-resident needs an Indian identifier first.
  • Form 26AS — India's consolidated statement of tax deducted, collected and paid against a taxpayer's identifier.
  • Form 5471 — The US information return for an interest in a foreign corporation, requiring foreign accounts restated to US principles.
  • Form 5472 — The US information return for reportable transactions between a US corporation, or a foreign-owned US disregarded entity, and its related foreign parties.
  • Form 3520 — The US return reporting transactions with foreign trusts and the receipt of large foreign gifts and bequests — an obligation missed precisely because the receipt is not income.
  • Form 8865 — The US information return for an interest in a foreign partnership, including contributions and dispositions.
  • Form 8858 — The US information return for a foreign disregarded entity or foreign branch owned by a US person.
  • Form 926 — The US return reporting a transfer of property to a foreign corporation — including capitalising the company you just formed.
  • FIRPTA — The US regime taxing a foreign person's disposition of US real property interests, enforced by withholding from the sale proceeds by the buyer.
  • Fixed place of business — The classic form of permanent establishment: premises, equipment or a facility at the enterprise's disposal through which business is carried on.
  • Foreign grantor trust — A non-US trust with a US settlor treated as grantor, bringing US information reporting and taxation of the trust's income to that settlor.
  • Forced heirship — Rules in some legal systems reserving part of an estate for particular heirs, which can override a will drafted elsewhere.
  • First-time penalty abatement — An administrative US waiver of certain penalties for a filer with an otherwise compliant history, requested rather than granted automatically.
  • Faceless assessment — India's electronic assessment process, conducted without a designated officer meeting the taxpayer and on deadlines running from the notice.
  • FEMA — India's exchange-control law, which defines residence differently from tax law and governs which accounts may be held and how funds may move.
  • FCNR account — A foreign-currency deposit for non-residents, which removes rupee exchange risk and has its own tax and repatriation treatment.
  • Form 15CA — The remitter's declaration of the tax treatment of a payment leaving India, filed before the bank will process the transfer.
  • Form 15CB — A chartered accountant's certificate on the taxability and withholding of an Indian outward remittance, delivered under a banking deadline.
  • Form 3CEB — The Indian accountant's report on international related-party transactions, mandatory regardless of transaction size.
  • FC-GPR — The Indian reporting of shares issued to a foreign investor, due within days of the transaction and compounding if late.
  • FC-TRS — The Indian reporting of a share transfer between a resident and a non-resident, on the same short clock as an issue.
  • Fixed fee — A fee agreed in writing before the work begins.
  • Form 1040-NR — The US non-resident return, reporting US-source income and income effectively connected with a US business.

What the F entries have in common

39 terms begin with F. What the entry under this letter turns on is set out on its own page, together with the returns it reaches and what we charge to handle them. Three to start with: Factual resident, FDAP income and Foreign earned income.

Nearby letters

E — 19 terms · G — 10 terms. The full A–Z lists all 297 terms in one place.

Back to the full glossary · Cross-border tax answers · Side-by-side comparisons

15+ years of cross-border experience

A cross-border question, quoted before we start

One short call, one fixed quote in writing, and your approval before anything is filed.

  • 18,000+ clients served
  • Fixed fees agreed before work starts
  • Offices in India, the USA, Canada and the UAE

Files that look like this one

Case study 1

Treaty Rate Refused Because the Paperwork Was Missing

A reduced rate under a treaty is available only where the payer is satisfied the recipient is resident in the treaty country. The certificate and the withholding form are what make the rate available at source instead of recoverable a year later.

Read how this one runs
Case study 2

Which Country Taxes the Salary

The employment article turns on where the work is done, who pays, and who bears the cost — three tests that can point in different directions. The file establishes all three before either return is drafted.

Read how this one runs
Case study 3

Canadian Dividends and Interest Paid to a Non-Resident

Flat withholding applies at source whether or not a return would produce the same figure. The engagement establishes treaty entitlement, files what is needed to claim the reduced rate, and recovers what went out at the domestic rate.

Read how this one runs
Case study 4

One Salesperson Abroad, and a Corporate Filing Obligation

A single employee with authority to conclude contracts can create a taxable presence for the whole company. The review tests what the person actually does against the treaty article, and where a presence exists, works out what profit is attributable to it.

Read how this one runs
Case study 5

Green Card Kept, Moved to Canada — Both Returns Still Due

Holding a green card does not end the US filing obligation, and living in Canada starts a Canadian one. The engagement fixes residence under the treaty tie-breaker, then decides which return the relief is claimed on so the two do not contradict each other.

Read how this one runs
Case study 6

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.

Read how this one runs
Case study 7

A Taxable Presence Created Without an Office

A dependent agent habitually concluding contracts can create a permanent establishment where there is no premises at all. The review tests what the person actually does against what the treaty describes.

Read how this one runs
Case study 8

Options Granted in India and Exercised Elsewhere

Where the grant, the vesting and the exercise happen in different countries, each may claim part of the same gain. Apportioning it across the period worked is what prevents the whole amount being taxed twice.

Read how this one runs

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

  • 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

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
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.

Request a Quote +1 (416) 619-0068