What makes software developers different from an ordinary filing?
A developer working remotely for a foreign employer can create a taxable presence for that employer in the country where the code is written — which turns a personal arrangement into the employer's problem. An ordinary preparer applies the general rule and stops there, which is how the relief in the specific provision goes unclaimed.
Can you work with my existing accountant?
That is how most of these engagements run. They keep the domestic file, we take the cross-border piece, and the boundary is agreed in writing so nothing is done twice or missed.
I work for a foreign employer — does that create problems for them?
It can, and this is the part developers are rarely told. Where you sit and write the code can be enough to give your employer a taxable presence in that country, either as a place of business or through a person habitually acting on its behalf there. If it is, the employer acquires a filing obligation, and possibly a payroll registration and a slice of profit to report, in a country it may have no other connection with. The exposure belongs to the company rather than to you, but it is discovered through your arrangement. Raise it before the contract is signed rather than after the first enquiry letter.
My employer has no company where I live — what are my options?
There are three common ones and they differ mainly in who carries the risk. The employer can register for payroll in your country without forming a company, which is the narrowest footprint that still gets tax and social contributions right. It can engage an employer of record, which puts a third party between you at a cost. Or you can contract as a genuinely independent business, which only holds if the substance matches: your own hours, your own equipment, more than one client, real commercial risk. Labelling an employment relationship as contracting does not change what it is, and reclassification usually lands on the employer.
I am paid in foreign currency into a foreign account — do I report it?
Yes, in your country of residence, converted into its currency, whether or not the money is ever brought there. Residence taxes worldwide income and the account being abroad changes nothing about that. Two things follow. The account itself may be separately reportable, because several systems require foreign accounts and assets to be disclosed with their own penalties quite apart from the tax on the income. And the conversion basis has to be consistent: use the rule your system prescribes, apply it to every payment in the year, and keep the rates and their source. Ad hoc conversion is what makes an otherwise correct return indefensible.
My share options vested after I moved — which country taxes them?
Usually both, in proportion. The prevailing approach looks at where you worked over the period the award was earned, typically between grant and vest, and gives each country the share of the gain relating to the work done there. So an option granted before a move and vested after it is split rather than assigned whole to either side. The practical difficulty is that each country also fixes its own taxing point, and the points rarely coincide: one may tax at exercise and the other at vest. Keeping the grant documents and a dated record of where you worked is what makes the apportionment provable later.
Does it matter which country I am sitting in when I write code?
Yes. Physical location is the fact almost every rule turns on. Employment income is generally sourced to where the duties are performed, so a month worked from another country is a month of income earned there, whatever the employer, the payroll or the bank account says. Your own residence is decided on days and ties. Your employer's exposure depends on where its work is habitually carried on. None of these follow the contract; they follow you. A developer who moves between countries during a year should keep a simple day log, because every one of those questions is answered out of it.
Am I an employee or a contractor for cross-border purposes?
The two countries decide separately, and they can disagree. Each looks at the substance: control over how and when the work is done, who supplies the equipment, whether you could send a substitute, whether you carry commercial risk, whether you serve other clients. A written contract calling you a contractor is evidence, not an answer. The classification matters more across a border than within one, because it decides which article of the treaty applies to your income, whether your employer has a payroll obligation where you sit, and which country's social security system you belong to. Settle it in writing at the start, with the facts recorded.
I have not filed for several years while living abroad — what are my options?
Both countries have routes back, and using one before they contact you is what preserves the relief. On the US side there are procedures aimed at taxpayers whose failure was not wilful, including one designed for people living outside the country, and separate procedures for late account reports and information returns alone. Canada has its voluntary disclosures programme and taxpayer relief for penalties and interest. Filing quietly and hoping is the one approach with no protection attached to it. See catch-up filing.
How does cross-border tax planning work?
It starts with facts rather than structures: which countries have a claim on you, what each one taxes, and where the two overlap. From there the decisions are about order and timing — which country taxes first, where relief is claimed, and whether a filing or a certificate has to be in place before money moves rather than after. Most of the value is in the sequencing, because relief claimed late is usually relief recovered slowly. See international tax planning.
