Cross-Border Tax (US-Canada and International)

Almost always yes. The treaty determines tax residence and which country gets primary taxation rights for each income type. We file the US return and coordinate with your Canadian preparer (or refer one) so the foreign tax credit flows correctly on both sides.

The IRS Streamlined Filing Compliance Procedures (Foreign Offshore version for non-US residents) typically allow 3 years of returns and 6 years of FBARs with no penalty for non-willful non-filers. We handle the full submission including the non-willful certification.

FBAR (FinCEN 114) is required if your aggregate foreign account balances exceed $10,000 at any point during the year. It is filed separately from Form 1040 with FinCEN. We file FBARs for every cross-border client where the threshold is crossed.

Foreign mutual funds (and most foreign ETFs) are PFICs under Section 1297, with punitive default tax treatment. Most clients are better off liquidating PFICs and reinvesting in US-domiciled funds. If keeping a PFIC, we make a QEF or MTM election to avoid the worst rates.

Section 877A treats covered expatriates as if they sold all worldwide assets the day before expatriation. We model the deemed-sale exit tax, time the expatriation date, and coordinate Form 8854 plus any deferred-comp and IRA distributions to minimize total tax.