U.S.-Canadian Dual Taxation Pitfalls: Reporting Issues and Planning Opportunities for U.S. Taxpayers
Navigating Tax Treaties to Minimize Tax on Passive Income and Pass-Through Income
About the Course
Introduction
This course will provide tax advisers with a thorough and practical guide to the tax reporting requirements and planning opportunities for U.S. taxpayers with earnings or assets in Canada, as well as Canadian citizens with U.S. tax reporting obligations. The panel will discuss U.S. tax law and treaty provisions designed to avoid or mitigate dual taxation, describe Canadian residency and expatriation rules, and detail the U.S. reporting and payment obligations specific to passive income as well as Canadian trade or business activity. The webinar will also provide helpful information on tax reporting of cross-border trust ownership.
Description
The Canada-U.S. border is the longest contiguous international border on earth. The geographical and demographic similarities between the two countries contribute to the world's most significant trade relationship between the two countries. Given these harmonious and long-standing relations, Canadian resident taxpayers frequently get caught up in the U.S. income tax system and vice versa.
A critical component of this cross-border business activity is avoiding dual taxation on income and gains. The U.S. and Canada have a comprehensive tax treaty system that addresses most dual taxation concerns. As in all international planning, tax advisers must understand the particular provisions to avoid an unpleasant tax bill—or maybe two.
Among the planning challenges for cross-border activities is navigating the tax treatment of LLCs and other U.S. disregarded entities. Canadian owners of U.S. LLC shares could face dual tax layers. Tax advisers for clients using LLCs will need to carefully plan on both sides of the border.
Other areas of concern in U.S.-Canadian tax planning include the treatment of passive income and tax considerations of cross-border pension ownership, contributions, and withdrawals. The extensive U.S. tax reporting requirements imposed on taxpayers with U.S. filing obligations are hovering over all these concerns.
Listen as our experienced panel provides comprehensive and practical guidance on navigating U.S.-Canada cross-border tax planning and reporting issues.
Presented By
Mr. Frisch is a dual licensed Chartered Professional Accountant who specializes in providing expert guidance and assistance to individuals navigating the complex landscape of cross-border taxation and financial planning, with a particular focus on the United States and Canada. With a deep understanding of both the US and Canadian tax systems, he helps individuals optimize their financial strategies to ensure compliance with the tax laws of both countries.
Ms. Kimmins is a member of the firm’s Business and International Tax Practices, where she advises businesses, individuals, and non-profit organizations on tax-related matters and planning. Prior to joining Hodgson Russ as an attorney, Ms. Kimmins worked for the firm on a part-time basis during her last year in law school and was also a summer associate.
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BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.
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BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).
Date + Time
- event
Thursday, January 7, 2027
- schedule
1:00 PM ET/10:00 AM PT
I. U.S.-Canada tax treaty overview and dual tax mitigation provisions
II. Treatment of U.S.-based LLCs and pass-through entities in cross-border situations
III. Passive and unearned income treatment
IV. U.S. tax reporting requirements of Canadian-sourced investments
V. Limitation of benefit provisions
The panel will discuss these and other relevant topics:
- Tax treaty provisions for mitigating dual taxation on ownership of cross-border LLCs and other pass-through entities
- Limitation of benefits clauses and provisions in the U.S.-Canada income tax treaty
- Key risks and challenges of passive/unearned income in cross-border situations, including an update on current Canadian legislative proposals with respect to Canadians earning passive income and new limitations on the deduction of interest in Canada
- U.S. reporting requirements of Canadian-sourced investment
Learning Objectives
After completing this course, you will be able to:
- Identify key provisions of the U.S.-Canadian income tax treaty
- Recognize the tax treatment of Canadian citizens owning an interest in a U.S. entity
- Establish the U.S. reporting requirements of Canadian-sourced investment
- Determine the limitations of benefits clauses and provisions in the U.S.-Canada income tax treaty
- Discern the tax implications of U.S. taxpayers owning shares in ULCs in Canada
- Identify tax planning opportunities to avoid double taxation and minimize the overall effective tax rate across the two countries
- Field of Study: Taxes
- Level of Knowledge: Intermediate
- Advance Preparation: None
- Teaching Method: Seminar/Lecture
- Delivery Method: Group-Internet (via computer)
- Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
- Prerequisite:
Three years+ business or public firm experience at mid-level within the organization, preparing complex tax forms and schedules, supervising other preparers/accountants. Specific knowledge and understanding of foreign information reporting requirements, including FATCA and FinCEN Form 114; familiarity with foreign income sourcing rules and tax treaty provisions.
BARBRI, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.
BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).
BARBRI CE webinars-powered by Barbri-are backed by our 100% unconditional money-back guarantee: If you are not satisfied with any of our products, simply let us know and get a full refund. Contact us at 1-800-926-7926 .
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