International & Cross-Border Tax

Overview

Cross-border tax is where the highest penalties live. $2,500 for a late T1135, the same again for every foreign affiliate left off a T1134, and 25% withheld at source where a treaty would have cut it to nothing, often on filings that produce no tax at all. It is also the corner of the Act most Canadian providers quietly avoid.

We work at that intersection daily. Non-residents holding Canadian real estate and corporations, Canadians with US entities, accounts, and property, US persons living in Canada, families arriving and departing, and groups that need both sides of a structure understood, not just the Canadian half.

In practice, that means information returns filed complete and on time, treaty positions taken with disclosure where required, withholding fixed at source instead of reclaimed years later, and planning done before a change in residency starts the clock. The cheapest cross-border problems are the ones prevented.

What's included

Non-Resident & Foreign-Owned Canadian Entities

T2 returns for non-resident corporations carrying on business in Canada, including treaty-based exemption reporting on Schedules 91 and 97, Regulation 105 and Regulation 102 withholding, and section 116 clearance certificates on dispositions of taxable Canadian property.

Foreign Asset & Affiliate Reporting

T1135 Foreign Income Verification Statements and T1134 returns for controlled and non-controlled foreign affiliates, with FAPI computations and T106 reporting on non-arm's-length transactions with non-residents, including Voluntary Disclosures where filings were missed.

Arrival & Departure Planning

Pre-arrival structuring and residency start-date planning for individuals moving to Canada, and departure tax on emigration. Deemed disposition, Forms T1243 and T1161, and part-year returns handled on both sides of the move.

Treaty Positions & Withholding

Positions under the Canada-US convention with NR301, NR302, and NR303 declarations and W-8 series documentation, Part XIII withholding and NR4 reporting, and section 216 rental elections with NR6 undertakings so withholding applies to net rather than gross.

US Persons in Canada

The reporting that catches Canadian residents holding US citizenship or a green card. TFSAs and RESPs treated as foreign trusts, Canadian mutual funds and ETFs caught by the PFIC rules, and RRSP treaty deferral, coordinated so both returns tell the same story.

Two tax systems. One firm that reads both.