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Ask us directlyTax Services Across United States
Files that look like this one
Federal and state filing obligations reconciled for a Canadian working across two US states
A Canadian professional split their US work assignment across two different states within the same year, and needed both states' residency rules applied separately alongside their federal filing. We reviewed the client's presence in each state, apportioned the income correctly, and prepared both state returns alongside the federal return with the credits and coordination between them properly reflected.
US citizen's worldwide filing obligation clarified after years of confusion about residence-based rules
A US citizen living abroad had assumed their filing obligation followed residence, the way most other countries' systems work, and had not filed for several years as a result. We explained the citizenship-based worldwide filing obligation, prepared the appropriate catch-up filing given the client's non-wilful circumstances, and brought the client's US compliance current.
Indian founder's first US entity structured with both federal and state obligations addressed
An Indian founder establishing their first US entity had only considered the federal corporate filing requirements, without reviewing which specific state the entity would need to register and file in. We reviewed the entity's planned operations, identified the appropriate state of formation and any additional states with a filing obligation, and set up the entity's compliance covering both federal and state requirements from formation.
Selling Into the US Without an Entity, and Filing in Several States
State obligations are set by each state, and a treaty does not reach them. The review measures activity against each state's own thresholds and separates the states where registration is required from the ones where it is not.
Read how this one runsOne Employee in a State Nobody Had Registered In
A single person working from home can create payroll registration, withholding and sometimes an income tax filing for the company in that state. The review measures activity against each state's own threshold.
Read how this one runsA 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 Country-by-Country Report and Who Files It
The obligation sits with the group and the filing can fall on a surrogate where the parent's jurisdiction does not exchange. Establishing who files where comes before preparing anything.
Read how this one runsAn Adjustment in One Country and No Relief in the Other
A pricing adjustment taxes the same profit twice unless the other country makes a corresponding one. The mutual agreement route is what produces that relief, and it is opened on a timetable set by the treaty rather than by either revenue authority.
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
Firms and partners working across borders meet Regulation 105 withholding, PE risk on long engagements and per-country payroll for travelling staff.
A partnership is taxed in the hands of its partners, so one engagement abroad can reach every partner's personal return. The order matters: the waiver is applied for before the invoice, the presence is tracked before it becomes an establishment, and the payroll is registered before the first day worked in the other country.
- 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
- Treaty access & PPT reviews
- FAPI & surplus computations
- Withholding-efficient routing
- Governance & substance
