If you have income, accounts or a business on both sides of the US-Canada border, you are filing into two systems, and neither tax authority accounts for the other's return.
Dimov Tax's cross border tax services put Canadian and US specialists on one file, so we settle your move date, your residency in each country and the source of each income item before we build either return.
We start with the date you moved and why, whether each country counts you as a resident that year, and where each income item came from. Then we list what you have in both countries:
The US and Canadian teams work from that one list, and neither borrows a classification or timing rule from the other.
For the Canadian rules themselves, see our Canada cross-border tax page. If you are a foreign national and what you need to settle is your US residency or visa status, start with our international tax consultant page.
You moved this year, or moved back. We fix the date, work out which country treats you as resident for which months, and settle both before we build either return.
You hold property or a portfolio in the other country. We match the rental, dividend, interest and capital-gain reporting to your foreign tax credit planning, and check which foreign-asset reports you owe.
You have RSUs or options vesting across a move, or you work remotely for an employer in the other country. We review the W-2 and T4 income, the equity, the employer withholding and any state return for the year you worked in both countries.
We confirm the facts each return depends on, and we work out whether a Canadian departure or arrival changes which returns you file. If your US residency status is in doubt, we settle that first.
We work out which returns you have to file for the year, a US Form 1040, a Canadian T1 personal return or both, and which of your W-2, T4, rental, investment and equity items belongs on each. A T2, the Canadian corporate return, is separate work.
Before we apply the US-Canada treaty, the US foreign tax credit or Canadian Form T2209, the federal foreign tax credit form, we settle which category the income belongs to, which country it came from, what tax you already paid, and which return we file first. Each country caps its own credits, so part of the income can still be taxed twice. Our cross border tax advisory work covers where that happens and what you can do about it under the rules.
When you leave Canada, the CRA treats you as having sold certain property the day you go, even though you still own it, and taxes the gain on the values you supply. We run that calculation, but we do not value private businesses ourselves. Registered plans, including RRSPs, TFSAs and locked-in accounts such as a LIRA, are excluded from that deemed sale, and we review each plan type separately for US tax.
As a Canadian resident you may owe Form T1135, the foreign property statement, if your specified foreign property cost more than CAD 100,000 at any point in the year. Cost is what you paid for it, not what it is worth today. As a US person you may owe an FBAR, the foreign account report filed with FinCEN, if your foreign accounts together passed US$10,000 at any point in the year, and Form 8938, the IRS foreign asset statement, has its own thresholds, which are higher and vary with where you live and how you file.
The two countries do not always classify the same company the same way. The CRA treats a US LLC as a taxable corporation, whatever the IRS does with it. If you own a US LLC or an S corporation and you are moving to Canada, we look at the entity in a separate consultation before we quote any corporate filing work.
If returns were missed on either side, we prepare the prior-year Canadian returns and the US returns under the Streamlined Foreign Offshore Procedures, open as of September 2026.
| STAGE | MOVE FACTS | INCOME, ASSETS & ENTITIES | RELIEF & FILING |
|---|---|---|---|
| PLANNING | Confirm move date and filing status in each country | Map wages, T4/W-2, investments, rentals, equity and entity interests | Sequence treaty positions, credits, payments and return work |
| U.S. | Carry the confirmed facts into the Form 1040 scope | Classify Canadian income and review foreign account data | Prepare credit calculations and screen FBAR/Form 8938 needs |
| CANADA | Apply those same confirmed facts to the T1 | Review specified foreign property and departure information | Prepare T1, T1135 or departure forms when included |
We make every one of these decisions from the same set of facts. You still file two separate returns.
Tax planning must be proactive if it is to be effective.
We collect prior returns, dates, income sources, W-2/T4 slips, account details, property and entity ownership.
We identify the US and Canadian personal returns, the supporting forms, any departure calculation and any foreign-asset report that apply to your situation.
We work out which treaty positions and credits you can claim, and which return to file first, before preparation starts. Once the year closes and both returns are due, we pass the work to our cross border tax accountant.
We quote Canadian T2 corporate preparation separately from your personal T1. It is never folded into the personal return.
Although my tax return involved multiple states and I moved outside the US, they dealt with it smoothly.
Our team includes CPAs and Enrolled Agents who work on individual returns, business taxes and tax planning. Tell us what you need help with when you get in touch.
Send us your move date, the countries involved, your income sources, account types, property and any business you own. Your quote will reflect how many returns there are, which reporting forms apply, any departure work, whether you need an entity consultation, and the state of your records.

Reviewed by George Dimov, CPA · individual and business income taxes · tax planning and strategy · 20 years in accounting · President and Managing Owner