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

Holly Haber Writes Article for the Jewish Foundation of Toronto

Fuller Landau Team • May 28, 2020

Holly Haber, Partner in our US Tax practice, recently authored an article for the Jewish Foundation of Toronto, where she outlined what US residents holding inheritances and cash gifts in Canadian investment accounts need to know. To read the full article, click here.

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COVID-19: Learn more about the US Government’s Paycheck Protection Program

Jeffrey Brown • April 02, 2020

COVID-19:  Learn more about the US Government’s Paycheck Protection Program The US Small Business Administration (SBA)’s Paycheck Protection Program (PPP) was created by The Coronavirus Aid, Relief, and Economic Security Act (the CARES Act) to help small businesses impacted by COVID-19. The CARES Act provides $349 billion of funding for SBA loan guarantees and additional

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COVID-19: US employment tax relief provisions explained

Jeffrey Brown • April 02, 2020

In this update, we explain the US employment tax relief enacted in recent COVID-19-related legislation. On March 31, 2020, IRS issued Notice 2020-22 outlining the following: The penalty relief applicable to deposits of US Federal employment taxes including income tax withheld, Federal Insurance Contributions Act (FICA) and Railroad Retirement Tax Act (RRTA) taxes (Employment Taxes);

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