US and Cross-Border Tax Accountant

Whether you’re a Canadian company with US business activities, a US business operating in Canada, or an individual, expatriate, or investor with interests in both countries, Fuller Landau can advise and help you manage the complexities of cross-border taxation.

Ongoing free trade negotiations prove the economies of Canada and the United States are essentially interconnected. Outsized nearly 10 to 1 in population, Canadian business needs to participate in the US marketplace to achieve critical volumes. And while less dependent, US companies look to Canada for financial and natural resources, innovation, and a highly-skilled labour pool.

Stakeholders mistakenly assume our shared border, language, and cultures translate into similar tax systems with any dissimilarities mitigated by the US Canada Tax Treaty. Such assumptions couldn’t be farther from the truth. Whereas Canadian federal and provincial taxes are generally integrated with one another, the US has one set of Federal tax laws (i.e., the Internal Revenue Code) and no national VAT tax (aside from specific federal excise taxes). State income tax laws often apply Federal tax principles, but each state is free to make its own modifications and is not required to follow the Treaty. And state sales taxation is not harmonized at the federal level or among the states. Thousands of localities impose their own tax rules, from income taxes to sales taxes.

Cautious stakeholders contemplate cross-border tax in their business plans from choice of entity and domicile to business registration and tax compliance. And for the aggressive entrepreneur who didn’t consider these things, remedial steps may mitigate tax and penalty exposures including voluntary disclosure.

Fuller Landau’s professionals can assist on both sides of the border, from advising on the optimal jurisdiction and type of entity, to registration with the Canada Revenue Agency, the Internal Revenue Service, and each state and localities where needed. We prepare Canadian and US federal and state tax returns. We work with Canadian and US attorneys.

For more information, contact us or meet our experts below.

Get In Touch

Please take a few moments to fill out the contact form, below, and let us know how we can help. We look forward to hearing from you!

Did You Know…

  • Fuller Landau’s US and Cross-Border Tax team is lead by partner Jeffrey Brown? He’s a former CFO from New York City with deep-rooted expertise in all matters pertaining to cross-border taxation.
  • Only about half of the US states apply the US Canada Income Tax Treaty to their income tax regimes, and the Treaty doesn’t apply to sales tax? Our team of experts is well-informed and ready to advise you, as needed.
  • Fuller Landau is an active member of Leading Edge Alliance? LEA is an international association of accounting, tax, and consulting firms, providing our clients with access to a global network of advisors.

US and Cross-Border Tax Recent Insights

COVID-19: US government signs CARES Act into law

Fuller Landau Team • March 29, 2020

On Friday March 27, 2020, President Trump signed the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) into law. The CARES Act includes several tax changes relevant to our clients including the following: Suspension of the 80% taxable income limitation on net operating loss (NOL) deductions for tax years 2018 through 2020 put into

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COVID-19: Temporary Wage Subsidy for Employers – Further Information

Fuller Landau Team • March 22, 2020

The Temporary Wage Subsidy for Employers was announced by the Government of Canada on March 18, 2020.  It is a three-month measure to assist eligible employers by reducing the amount of payroll deductions required to be remitted to the Canada Revenue Agency (CRA). An eligible employer is a Canadian-controlled private corporation (CCPC), a non-profit organization

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IRS: Notice 2020-18: Federal income tax deadline extension for filing and payment

Fuller Landau Team • March 22, 2020

On Friday evening, March 20, 2020, Internal Revenue Service (IRS) released an advance copy of Notice 2020-18 (superseding Notice 2020-17) automatically extending the federal income tax filing and payment due dates for certain federal income taxes from April 15, 2020 until July 15, 2020. Notice 2020-18 applies to individuals, trusts, estates, partnerships and corporations. Taxpayers

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