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Canada US cross border tax returns filed on both sides

You have income, or a move, on both sides of the border, and two revenue agencies that do not define your income the same way. We prepare the Canadian return and the US return in one file, so the credit each country gives for the other is right the first time.

  • Both returns prepared in one place, in the same year, by one team

  • Move years covered: residency dates, departure tax, split year reporting

  • Registered accounts, foreign property and account disclosure filed on the correct side

Tax rules to know before moving between Canada and the US

  • Canada treats the day you stop being a resident as a sale of certain types of property, whether or not you sold anything.

  • A US citizen or green card holder keeps filing US returns after a move abroad while that US tax status continues.

  • Disclosure can be the expensive part of a cross border year: the IRS and the CRA penalize a missing form even in a year with no tax to pay.

What cross border filing between Canada and the US involves

Canada US cross border tax planning and filing means preparing and reconciling two returns for one person in the same year: a Canadian T1 with the Canada Revenue Agency and a US return with the IRS. Canada taxes on residency. The US taxes its citizens and green card holders wherever they live.

That difference is why a Canada US tax accountant needs both sides of the file. A preparer who sees only the Canadian return cannot tell you whether the IRS will allow the credit you claimed. A preparer who sees only the US return will not know that leaving Canada created a capital gain on shares you still hold. We hold both files, and Canadian tax staff on our own team prepare the Canadian return.

This is tax preparation, planning and reporting. We do not give legal or immigration advice, and the tax authorities decide residency for tax purposes separately from immigration status.

Who prepares your Canada and US returns

  • Canadian tax staff in house prepare the T1

  • CPAs and Enrolled Agents on every return

  • IRS Certifying Acceptance Agents for ITIN applications

  • A fixed quote agreed before any work starts

Who needs to file in both Canada and the US

Which returns you owe in US Canada cross border tax work depends on your facts.

  • Moving to the US from Canada:

    tech and finance staff on TN, H-1B or L-1, with Canadian shares, an RRSP and a departure year to close out.

  • Moving to Canada from the US:

    US citizens and green card holders who keep filing with the IRS after the move, plus anyone bringing a 401(k), IRA or Roth IRA, or a US LLC or S corporation, with them.

  • Canadians earning US income:

    contractors, consultants and remote workers serving US clients, and athletes, speakers and performers paid for work done on US soil.

  • Americans living in Canada:

    long term residents who file a T1 in Canada and a 1040 in the US each year and need the credits on both returns to match.

  • Cross border property owners and investors:

    rental income in the other country, a US property sold by a non-resident, and non-registered portfolios with a cost above the CAD 100,000 T1135 threshold.

  • Retirees paid across the border:

    CPP, OAS or US Social Security received while resident in the other country, and RRIF, 401(k) or IRA withdrawals.

Where the move involves a US LLC or an S corporation, a senior reviews the entity before any quote, because Canada and the US do not always classify the same company the same way.

Tax residency dates for a move between Canada and the US

Your tax residency dates can differ from the day you move, and the Canadian date and the US date can differ from each other.

On the Canadian side you usually become a non-resident on the latest of three dates:

  • the day you leave Canada
  • the day your spouse and dependents leave Canada
  • the day you become a resident of the new country

The CRA sets that out on its emigrants page, and you enter the date on page 1 of the departure year return.

On the US side, tax residency can start under the green card test or under the substantial presence test: at least 31 days in the US this year and 183 weighted days across this year, one third of last year and one sixth of the year before. Someone who visited heavily in the two prior years can pass the test in a year with far fewer than 183 days in the US.

Get either residency date wrong and the returns can be wrong in opposite directions. It is cheap to fix before filing and expensive to fix afterwards.

Residency dates can differ

Canada and the US use different residency rules. Your Canadian residency can end on one date and your US tax residency begin on another.

  • Resident periodWorld income reported to the CRACanada / CRA
  • Non-resident periodCanadian-source income onlyCanadian departure date
  • Non-resident periodUS-source income onlyUnited States / IRS
  • Resident periodWorldwide income reported to the IRSUS residency start
If both countries treat you as resident for the same period, the treaty tie breaker rule applies.

Four filings to check in a Canada US cross border year

Disclosure forms are a cost separate from the two returns.

Canadian departure tax.
When you leave Canada, the CRA treats certain types of property as sold at fair market value on the departure date, whether or not you sold anything. Where the total fair market value of the property you owned on that date was over CAD 25,000, the CRA also requires Form T1161, the list of property held on departure, even in a year with no tax to pay.
Foreign property reporting.
A Canadian resident whose specified foreign property cost more than CAD 100,000 at any point in the year files Form T1135. The threshold is measured on cost, not current value, so a US brokerage account that has fallen in value can still be reportable.
Registered accounts.
Under Rev. Proc. 2014-55, the IRS treats an eligible individual as having elected to defer US tax on income accruing inside an RRSP or RRIF and no longer requires Form 8891. FBAR, the foreign account report filed with FinCEN, and Form 8938, the IRS foreign asset statement, still apply, and a TFSA receives no equivalent deferral.
Selling US property as a non-resident.
The buyer generally has to withhold 15% of the gross amount realized on a sale by a foreign person. Applying for a withholding certificate before closing can reduce the amount sent to the IRS.

None of the four depends on how much tax you owe; three apply in years with no tax to pay.

Have the departure year checked before it is filed

Send the move date, a list of what you held on that date, and last year's returns from both countries. We tell you which of the four filings apply to you before we prepare anything.

What we file with the CRA and the IRS

  • Canadian T1, including the departure year: split into a resident and a non-resident period, with Form T1243, the deemed disposition schedule, and Form T1161 where the deemed disposition applies.
  • US Form 1040 or Form 1040-NR: including the dual status return the IRS requires for a year you were resident for only part of it.
  • Foreign tax credits both ways: Form 1116 on the US side and the equivalent Canadian claim, computed together so the credits match.
  • Account and asset disclosure: FBAR, Form 8938 and Form T1135, each on its own threshold and its own deadline.
  • Treaty positions: disclosed on Form 8833, the treaty position statement, where the IRS requires disclosure.
  • US property sales by non-residents: the withholding certificate application before closing and the return afterwards to reclaim any excess withheld.
  • Missed years on either side: the Streamlined Foreign Offshore Procedures for the US return, open as of September 2026, and prior-year Canadian returns.
  • T1 (departure year)Split into resident and non-resident periods, with the departure date on page 1.Filed with the CRA
  • T1243Gain on property treated as sold on the day Canadian residency ended.Filed with the CRA
  • T1161Property held on departure, where total fair market value is over CAD 25,000.Filed with the CRA
  • T1135Filed when a Canadian resident holds specified foreign property with a total cost over CAD 100,000 at any point in the year.Filed with the CRA
  • 1040 or 1040-NRYou file the 1040 as a US resident and the 1040-NR as a non-resident; the first year can be dual status.Filed with the IRS
  • Form 1116Credit for Canadian tax paid on the same income.Filed with the IRS
  • FBAR + Form 8938Account and asset disclosure. Separate thresholds and separate filing rules.Filed with the IRS
  • Form 8833Treaty positions, where the IRS requires disclosure.Filed with the IRS
Registered accounts are reported on both sides.

How we prepare a Canada US cross border file

We fix the scope and the price in the first two of the six steps.

  1. Residency call.

    Move dates, visa type, income sources in each country, and what stayed behind. We confirm from these which returns you owe.

  2. Scope and quote.

    Agreed in writing before work starts, based on the returns and forms that apply to your facts.

  3. Documents.

    Prior year returns and notices of assessment from both countries, slips, and for a departure year the cost base and fair market value of what you held on the move date.

  4. Canadian return.

    Prepared first where a departure year is involved, because we carry the deemed disposition figures into the US return.

  5. US return and credits.

    Prepared using the Canadian figures, so the foreign tax credit matches the Canadian tax paid.

  6. Disclosure filings.

    FBAR, Form 8938 and Form T1135 filed on their own deadlines, which do not all match the return deadline.

Where you are moving from Canada, we cannot start the departure calculation without the stock detail in step three: name, share count, cost base and fair market value on the day of the move.

What Canada US cross border tax work costs

Priced on the returns and forms your facts produce, not on time spent. What we quote against:

  • Whether one country or both are in scope for the year
  • Whether it is a full year on one side or a split year on both
  • Whether a deemed disposition applies, and how many holdings need a value on the move date
  • How many accounts cross the disclosure thresholds
  • Whether a US LLC, S corporation or rental property is involved

These are the factors, not a quote.

What our clients say

Anytime you have a major change in your situation, whether it's your family situation, whether it's your work, whether it's income or source of income, you want to speak with the tax adviser and make sure that everything that you're doing now continues to make sense in the future.

George Dimov, CPA

Would highly recommend. Been a client for many years and always quick and efficient service. They also have specialists on Canadian tax code for those with tax obligations in both countries.

Laith KamaleddineGoogle review

Meet the Dimov Tax team

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.

Talk to someone who files both returns

Tell us the move dates, where the income comes from, and what you hold. We will tell you which returns you owe and quote before any work starts.