US–Canada tax preparation at a glance
Bluewings Tax offers a coordinated filing review for people whose lives involve both countries. Whether you call it US–Canada or Canada–US filing, begin with the same facts and agree the work before preparation.
- Who it is for: people moving, working, investing or holding accounts and ownership interests across the border.
- What the review covers: the US federal/state and Canadian returns, residency questions and any separate reporting to be included in your engagement.
- What happens next: an initial review, written scope and quotation, requested records through your client portal, then review of the prepared work before filing.
- What to confirm: the tax years, country returns, information reports, assigned professional, fee and currency. Ask separately about earlier years, corrections and representation.
Meet the team and read our guide standards · Prepare your cross-border checklist
US–Canada and Canada–US tax filing: choose your starting point
Official guidance checked October 31, 2026. Start with the move direction and citizenship or residency history; the same border crossing does not create the same return requirements for everyone.
Moving from the US to Canada
Canadian tax obligations depend on residency and residential ties, rather than immigration permission alone. Keep the dates your home, spouse or partner and dependants moved, plus income and relevant property records around the residency change. Use the CRA newcomer guidance and our Canadian T1 filing guide to organize the review.
A US citizen or resident alien living in Canada generally remains subject to US tax rules on worldwide income. Possible credits or exclusions do not make a Canadian return replace the US filing review. See the IRS guidance for US taxpayers abroad. Identify citizenship and green-card history before deciding the US return scope.
Moving from Canada to the US
Leaving Canada does not, by itself, settle Canadian residency. Review retained homes and family ties, possible treaty treatment and any departure-year obligations. Certain property may require a deemed-disposition review even without a sale; use the CRA emigrant and departure-tax guidance before assuming that every asset has the same treatment.
On the US side, assess citizenship, the green-card test, the substantial presence test and any applicable exception or treaty position. The IRS presence test uses a weighted three-year count, with a current-year condition and excluded-day rules. Regular qualifying commuter days from Canada can be excluded; crossing the border does not automatically establish US tax residency.
Which country should I choose when contacting Bluewings?
Choose the country where you primarily need preparation, then describe both countries and the tax years. One enquiry can request a coordinated review; it does not include both countries' returns until the written scope says so.
Keep identity numbers and tax documents out of the initial enquiry. Use your private client portal for requested records after onboarding.
Three checks before coordinating US–Canada returns
Does the treaty mean I only file in one country?
Do not assume that treaty relief removes a return or disclosure requirement. Eligibility depends on residency, income and the relevant provision; US state treatment can differ. Review the IRS treaty overview alongside the country-specific guidance below.
Are income returns and foreign-account reports the same work?
No. Assess US and Canadian income returns separately from US FBAR/Form 8938 and Canadian T1135 reporting. The forms have different coverage and thresholds. Use our FBAR and Form 8938 guide and the CRA T1135 overview to prepare questions, then confirm the forms included in your engagement.
Are Canadian retirement accounts automatically exempt from US reporting?
No. Relief for certain eligible RRSP/RRIF holders does not remove otherwise applicable FBAR or Form 8938 obligations. The IRS US–Canada treaty publication explains this distinction. List each plan and account type separately; do not extend RRSP/RRIF treatment to a TFSA or another account without a specific review.
Tax preparation when your life crosses the US–Canada border
Discuss your US–Canada filingStart with your cross-border situation
Moving between countries
Arrival and departure years, time spent in each country, homes and family ties, and income earned before and after a move.
Working across the border
Commuters, remote workers and people with employers or clients in the other country who need their employment and filing circumstances assessed.
Income, investments and ownership
People with investments, pensions, rental property or business interests on both sides of the border. Tell us the account and entity types before requesting a quote.
Residency comes before the return
Canadian tax residency considers the relevant facts, including residential ties; a move date alone does not answer every case. US residency uses different rules, and treaty provisions may matter where both countries treat someone as resident. Start with the CRA residency guidance and the IRS explanation of tax and immigration status.
Before preparation, we assess the relevant US federal/state and Canadian return scope, income categories, taxes already paid and possible additional reporting. Confirm the returns and any cross-border analysis included in your engagement.
Questions to flag at the start
- Did you arrive in or leave either country during the tax year?
- Where did you physically perform employment or self-employment work?
- Do you have pensions, retirement accounts or other investment accounts in the other country?
- Do you own rental property or an interest in a business outside your country of residence?
- Have you received a notice or missed a return or information-reporting requirement?
The IRS US–Canada treaty publication and CRA treaty guidance are useful starting references. Treaty relief, pension treatment and foreign tax credits depend on the applicable rules; do not assume that an account’s treatment in one country automatically carries over to the other.
Documents for an initial review
- Prior US and Canadian returns and relevant tax notices.
- Move/travel dates and information about homes and family ties.
- US W-2/1099 documents and Canadian income slips, as applicable.
- Employment location details, rental records, investment and pension statements, and taxes paid.
- Foreign-account details and business ownership/accounting information where relevant.
FBAR and Form 8938 have separate rules. Neither filing automatically replaces the other. Consult the IRS comparison; your case determines which reporting is needed.
How cross-border work is priced
Review our current US preparation prices and Canada preparation prices for the stated services and eligibility terms. Published country prices are not a combined US–Canada package; obtain a case-specific quote before work starts.
Canadian preparation and additional cross-border analysis must be included explicitly in your quote, with the currency stated. Final fees depend on forms, records, tax years and complexity. FBAR and FATCA services are excluded from discounts.
US–Canada filing questions
Does moving to the US automatically end Canadian residency?
No. Review your residential ties and all relevant circumstances. Treaty provisions may also affect the result. See the CRA guidance for people leaving Canada.
Can I use the same income figures on both returns?
Do not simply copy a return from one country to the other. The reporting period, residency, currency conversion and treatment of particular income may differ. Provide source documents for coordinated preparation.
Can you assess a previous year or a tax notice?
Include the year and a brief description in your enquiry. We will confirm whether the work is within scope and quote it separately where needed. Upload sensitive documents through the portal when requested.
Explore cross-border filing guides
Prepare one coordinated review, with a clear scope
- Build a residency and work timeline. Record move dates, travel, homes and family ties, plus where work was physically performed. Include the states and provinces involved.
- Keep each country’s source records. Organize income slips, taxes paid, investments and account types by year and currency. Avoid replacing original figures with a single converted total.
- Agree the engagement in writing. Confirm country returns, tax years, information reports, any treaty analysis, the fee and its currency. Flag notices and missing years at the start.
Build your Canada cross-border checklist ↗
Build your US cross-border checklist ↗
Choose the checklist for your primary service country. It is a preparation aid, not a filing determination. Share sensitive records through the private client portal after onboarding.
How to get started
- Tell us your situation. Start with the countries involved, the tax years you need help with and whether you are filing as an individual or business.
- Confirm the scope and quote. We assess the forms and documents involved before confirming the work and fee.
- Provide documents through the client portal. Follow the checklist for your case and review the prepared return before filing.
Bluewings Tax’s review team includes Aditya and Soumya. Ask who will handle your case and which services are included in your engagement.
Request a cross-border consultationGeneral service information. Updated October 31, 2026. Requirements depend on your facts and the applicable tax year.