12+ years serving Ontario | CPA Ontario registered | Free initial consultation

What we handle

Serving Woodbridge, Brampton, and Kitchener
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    Years of CPA excellence

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    Clients served across Ontario

  • Office locations in Ontario

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    Google rated by real clients

The Problem

The U.S. taxes Canadians even when they live, work, and pay tax here.

Most Canadians are surprised to learn that U.S. tax obligations follow citizenship and certain residency connections, not just where you currently live. If you are a U.S. citizen or green card holder living in Canada, you likely have annual U.S. filing obligations regardless of whether you owe any U.S. tax. The same applies if you have U.S. income, U.S. bank accounts above certain thresholds, or a business with U.S. operations.

The penalties for non-compliance are serious, and many Canadians with U.S. ties have simply never been told they had an obligation. The good news: there are IRS programmes specifically designed for non-willful non-filers that allow you to catch up with reduced or waived penalties. We have helped many clients come into compliance cleanly and without the drama they feared.

  • Not knowing you have a U.S. filing obligation

    Many Canadians with U.S. citizenship, a U.S. green card, or U.S. bank accounts are unaware they have annual IRS filing requirements. Years of non-filing accumulate penalties that grow quietly in the background.

  • FBAR and FATCA penalties are severe

    Failing to report a foreign bank account with more than $10,000 USD at any point in the year can result in FBAR penalties of up to $10,000 USD per violation for non-willful failures. Willful violations are higher. These are not theoretical: the IRS actively enforces them.

  • Canada and U.S. tax rules conflict in unexpected ways

    RRSPs, TFSAs, principal residence exemptions, and Canadian corporate structures are all treated differently by the IRS and CRA. Without proper planning, you can end up paying tax in both countries on the same income.

  • Using a regular tax preparer for a cross-border situation

    Most Canadian tax preparers do not file U.S. returns and are not equipped to advise on cross-border issues. Using one for a situation that requires both countries covered is the fastest way to create an expensive problem.

Our U.S. Tax Services

Complete U.S. and cross-border tax coverage for Canadians.

Select a category to explore what we offer. Not sure if your situation applies? Book a free consultation and we will tell you exactly what you need.

1040 U.S. Individual Tax Return

Annual U.S. income tax filing for U.S. citizens, green card holders, and certain long-term residents living in Canada. We prepare and e-file your 1040 and coordinate with your Canadian T1 to minimise double taxation.

  • Employment and self-employment income
  • Investment and rental income
  • Foreign tax credit claims (Form 1116)
  • Foreign earned income exclusion (Form 2555)
  • Treaty-based positions

FBAR Filing (FinCEN 114)

If you have a financial interest in, or signature authority over, one or more foreign bank accounts with an aggregate value exceeding $10,000 USD at any point in the calendar year, you must file an FBAR. We prepare and submit this electronically through the BSA E-Filing System.

  • Canadian bank and investment accounts
  • RRSPs and TFSAs held as foreign accounts
  • Business accounts held outside the U.S.
  • Joint accounts and accounts with signature authority

FATCA Form 8938 Foreign Asset Disclosure

FATCA requires U.S. persons to report specified foreign financial assets above threshold amounts on Form 8938, which is filed with the 1040. This is separate from and in addition to the FBAR requirement.

  • Foreign bank accounts
  • Foreign investment accounts
  • Interests in foreign entities
  • Foreign pension plans and deferred compensation
  • Thresholds based on filing status and residency

Canada-U.S. Tax Treaty Planning

The Canada-U.S. Tax Convention contains provisions that eliminate or reduce double taxation on many types of income. We identify and claim all applicable treaty benefits and file the required treaty-based disclosures with both the IRS and CRA.

  • Treaty exemptions on specific income types
  • Tiebreaker rules for dual residents
  • Treaty benefits for RRSPs and pensions (Revenue Procedure 2014-55)
  • Article XXV non-discrimination provisions

Dual-Status Year Returns

In the year you move to or from Canada, your U.S. tax filing status changes mid-year. Dual-status returns are complex and require careful handling to avoid errors and missed elections that cannot easily be corrected later.

  • Year of departure from the U.S.
  • Year of arrival in Canada or the U.S.
  • Resident and non-resident periods
  • Optimal elections to minimise tax in the transition year

State Tax Return Filing

Depending on your prior U.S. state of residence and the nature of your income, you may have state-level U.S. tax obligations in addition to your federal 1040. We assess state nexus and file where required.

  • Prior state residency obligations
  • State-source income from U.S. property or employment
  • States with no income tax and filing exceptions
  • State conformity to federal treaty positions

Canadian Business with U.S. Customers or Operations

If your Canadian corporation earns income from U.S. sources, has U.S. employees or contractors, or maintains any kind of U.S. presence, you may have U.S. federal and state tax obligations. We assess and manage your exposure.

  • Permanent establishment analysis
  • Effectively connected income (ECI) determination
  • U.S. branch tax obligations
  • Withholding tax on U.S.-source payments
  • Treaty-based exemption claims

U.S. LLC and Corporation Filing

Canadians who own or co-own U.S. LLCs, S-corps, or C-corps have annual U.S. filing requirements regardless of whether the entity generated income. We prepare entity-level returns and advise on the Canadian tax treatment of the income.

  • Form 1120, 1120-S, and 1065 preparation
  • Schedule K-1 for pass-through income
  • PFIC analysis for Canadian-controlled U.S. entities
  • Form 5471 for Canadians owning shares of U.S. corporations

Non-Resident Withholding Tax (Section 1441)

U.S.-source income paid to Canadian residents is generally subject to U.S. withholding tax. We advise on applicable rates, treaty reductions, exemptions, and the process for claiming refunds of over-withheld amounts.

  • Dividends, interest, royalties, and service income
  • Treaty-reduced withholding rates
  • Form W-8BEN and W-8BEN-E completion
  • ITIN application support
  • Form 1040NR for non-resident returns

ITIN Application (Form W-7)

Non-U.S. citizens who have a U.S. tax obligation but are not eligible for a Social Security Number require an Individual Taxpayer Identification Number (ITIN). We prepare the W-7 application and certify supporting documents.

  • First-time ITIN applications
  • ITIN renewal for expired numbers
  • Certified acceptance agent services
  • Supporting document requirements
  • Processing timelines and expectations

Cross-Border Employment Tax

If you are a Canadian resident working for a U.S. employer, or a U.S. citizen employed by a Canadian company, your employment income requires careful handling under both the Canada-U.S. Tax Convention and the Canada-U.S. Social Security Totalisation Agreement.

  • U.S. employer payroll withholding obligations in Canada
  • CPP and Social Security totalisation
  • Commuter workers and frequent cross-border employees
  • Remote work for U.S. companies

U.S. Real Estate (FIRPTA)

Canadians selling U.S. real property are subject to the Foreign Investment in Real Property Tax Act (FIRPTA), which requires U.S. withholding tax on the gross sales price. We advise on FIRPTA withholding obligations, exemptions, and refund claims.

  • FIRPTA withholding on property sales
  • Withholding certificates to reduce withholding
  • Form 8288 and 8288-A preparation
  • Form 1040NR filing for U.S. property income or sale proceeds
  • Depreciation recapture

Streamlined Foreign Offshore Procedure (SFOP)

The Streamlined Foreign Offshore Procedure is an IRS amnesty programme for U.S. persons living outside the U.S. who are non-willfully non-compliant. It allows you to file three years of delinquent tax returns and six years of FBARs with no penalties. Most of our Canadian clients qualify for this programme.

  • Eligibility assessment and compliance history review
  • Preparation of three years of 1040 returns and six years of FBARs
  • Delinquency penalty waiver under SFOP
  • Certification of non-willfulness

Streamlined Domestic Offshore Procedure (SDOP)

For U.S. persons residing inside the U.S. who are non-willfully non-compliant, the SDOP programme allows catch-up with a 5% miscellaneous offshore penalty instead of the full penalty schedule. We assess which programme applies to your specific situation.

  • Eligibility comparison between SFOP and SDOP
  • Preparation of required returns and amended filings
  • 5% miscellaneous penalty calculation
  • Certification and submission requirements

Delinquent FBAR Submission Procedure

If you have no unreported income but have simply missed filing FBARs, the Delinquent FBAR Submission Procedures allow you to file late FBARs without penalty. We prepare and submit all outstanding FBAR filings along with the required explanation of late filing.

  • Late FBAR filing submission through BSA E-Filing
  • Explanation statement for delinquent submission
  • Six-year lookback period coverage
  • Records and documentation review

IRS Audit Representation

Received a notice from the IRS? We represent you throughout the examination process, prepare all required documentation, correspond with the IRS on your behalf, and advise on the best resolution strategy for your specific situation.

  • IRS correspondence and notice response
  • Audit examination representation
  • Document preparation and review
  • Appeals process if required
  • Penalty abatement requests

Prior-Year 1040 Back Filing

If you are behind on U.S. tax returns but do not qualify for or choose not to use a streamlined programme, we prepare and file all outstanding 1040 returns with appropriate penalty abatement requests where applicable.

  • Multiple-year 1040 preparation
  • First-time penalty abatement requests
  • Reasonable cause penalty relief arguments
  • Coordination with CRA records for foreign tax credits
  • Payment plan guidance

PFIC Analysis and Reporting

Passive Foreign Investment Companies (PFICs) are one of the most complex and costly traps for U.S. persons holding Canadian mutual funds, ETFs, or non-U.S. investment vehicles. We identify PFIC holdings and advise on the available elections to manage the tax impact.

  • Identification of PFIC holdings in Canadian portfolios
  • QEF and mark-to-market election analysis
  • Form 8621 preparation
  • RRSP treaty election for PFIC relief
  • Restructuring of investment holdings to reduce PFIC exposure

HOW IT WORKS

Cross-border tax is complex. Your path through it does not have to be.

From your first call to a filed and confirmed return, here is how we work through a cross-border tax situation with you.

1

Discovery Call

We assess your full cross-border situation: citizenship, residency history, income sources, account holdings, and prior filing history. This determines exactly what is required before any work begins.

2

Obligation Assessment

We map out every filing requirement for both the IRS and CRA, identify any periods of non-compliance, and advise on the most appropriate path forward, including amnesty programmes if applicable.

3

Document Collection

We send a tailored checklist covering all required information for your U.S. and Canadian filings. You provide documents securely online or at any of our three office locations

4

Preparation and Coordination

Our team prepares your U.S. returns in coordination with your Canadian filings, applies all available treaty benefits and foreign tax credits, and reviews everything for accuracy before submission.

5

Filed and Confirmed

We submit electronically to the IRS and BSA E-Filing System, provide you with confirmation of all submissions, and advise on any ongoing obligations for future years.

Who We Serve

You do not need to be wealthy or live in the U.S. to have a U.S. tax obligation.

Cross-border tax obligations arise from citizenship, residency history, income sources, and financial account holdings. We serve Canadians across all of these situations, from straightforward annual filers to complex multi-year catch-up cases.

  • U.S. Citizens Living in Canada

    You are a U.S. citizen who has lived in Canada for years or decades. You may have never filed a U.S. return, or you may have filed inconsistently. Either way, we can assess your situation and get you compliant.

  • Dual Citizens (Canada and U.S.)

    You hold both Canadian and U.S. citizenship and have tax obligations to both countries. We coordinate your Canadian T1 and U.S. 1040 filings to apply all available treaty benefits and avoid double taxation.

  • Canadians with U.S. Bank Accounts

    You are a Canadian citizen or permanent resident who has U.S. bank accounts, brokerage accounts, or other U.S.-held financial assets above reporting thresholds. FBAR and potentially FATCA obligations apply.

  • Canadians Working for U.S. Employers

    You are a Canadian resident employed by a U.S. company, working remotely or cross-border. Your U.S.-source employment income creates both Canadian and potentially U.S. filing obligations.

  • Canadian Businesses with U.S. Operations

    Your Canadian corporation has U.S. customers, employees, or a physical presence. We assess permanent establishment risk, U.S. withholding obligations, and required entity-level U.S. filings.

  • U.S. Persons Returning to or Arriving in Canada

    You recently moved from the U.S. to Canada, or moved back to Canada after living in the U.S. Your transition year return requires careful handling of dual-status periods, departure tax, and available elections.

Do you have a U.S. tax obligation? You might be surprised.

The situations below are the most common triggers we see. If any of them apply to you, a free 20-minute consultation will tell you exactly where you stand.

Free consultation. No commitment required.

12+

Years in Practice

Serving Ontario clients with U.S. tax obligations since 2012.

3

Ontario Offices

Woodbridge, Brampton, and Kitchener: in-person or virtual, wherever you are.

500+

Clients Served

From first incorporations to complex business sales and succession plans.

5-Star

Google Rating

Our clients rate us five stars, and many have been with us for over five years.

Common Questions

Cross-border tax questions
we hear most often.

If your situation is not covered here, a free 20-minute consultation will give you a clear answer. No obligation.

Call 905-605-5272 or email info@johricpa.ca

You are not alone: this is one of the most common situations we handle. U.S. citizens are required to file annual U.S. tax returns regardless of where they live, and many Canadians with U.S. citizenship are simply unaware of this. The IRS offers the Streamlined Foreign Offshore Procedure (SFOP), an amnesty programme specifically designed for non-willful non-filers living outside the U.S. Under SFOP, you file three years of back returns and six years of FBARs with no penalties. Most of our clients qualify. Book a free consultation and we will assess your situation before any work begins.

FBAR stands for Report of Foreign Bank and Financial Accounts (FinCEN Form 114). If you are a U.S. person and you have a financial interest in, or signature authority over, one or more foreign financial accounts with an aggregate value exceeding $10,000 USD at any point during the calendar year, you must file an FBAR annually by April 15 (with an automatic extension to October 15). This applies to Canadian bank accounts, RRSPs, TFSAs, and Canadian brokerage accounts. FBAR penalties for non-willful failures can reach $10,000 USD per violation. We file these electronically through the BSA E-Filing System.

Not if your situation is handled correctly. The Canada-U.S. Tax Convention contains provisions specifically designed to prevent double taxation. In most cases, taxes paid to Canada are creditable against your U.S. liability through the Foreign Tax Credit (Form 1116), and vice versa. For Canadian residents, Canadian taxes on employment and business income generally exceed U.S. taxes, resulting in a full foreign tax credit with no additional U.S. tax owing. However, certain types of income and certain situations such as TFSAs and Canadian mutual funds are treated very differently by the two systems and require careful planning.

If you are a Canadian resident (not a U.S. citizen or green card holder) working remotely from Canada for a U.S. employer, your employment income is generally sourced to Canada under the Canada-U.S. Tax Convention because you are performing the work in Canada. You would not typically owe U.S. income tax on that income, though your employer may still be withholding U.S. federal and state taxes from your paycheque. If so, you would be entitled to a refund of those withholdings by filing a Form 1040NR. If you are a U.S. citizen or green card holder, additional U.S. filing obligations apply regardless of where you perform the work.

A Passive Foreign Investment Company (PFIC) is a non-U.S. entity that earns mostly passive income. Most Canadian mutual funds and many ETFs qualify as PFICs under U.S. tax law. The default IRS tax treatment of PFICs is extraordinarily punitive: gains are taxed at the highest ordinary income rates plus an interest charge that can eliminate most of the economic gain. However, U.S. persons holding PFICs through a Canadian RRSP are protected by the Canada-U.S. treaty, and for other accounts, a Qualified Electing Fund (QEF) or mark-to-market election can significantly reduce the tax impact. This is one of the most consequential issues for U.S. citizens living in Canada, and we advise on it as a standard part of any cross-border engagement.

IRS notices range from routine requests for information to formal audit examinations. The most important thing is not to ignore it and not to respond without first speaking to someone who handles U.S. tax. The notice will have a response deadline and the IRS does follow up if you miss it. Send us a copy and we will assess the situation, advise you on what is required, and manage the correspondence on your behalf. In many cases, IRS notices are straightforward to resolve with the right response.

Both. This is one of the most important reasons to work with a CPA firm that handles cross-border tax rather than a U.S.-only tax preparer. Your Canadian T1 return and your U.S. 1040 return must be coordinated: foreign tax credits, RRSP reporting positions, treaty elections, and income characterisation all interact between the two filings. Preparing one without the other is how costly mistakes happen. Our team prepares both, in the same engagement, so nothing falls through the gap between the two systems.

Most cross-border tax situations are more manageable than they appear. Let us show you what yours looks like.

Whether you have never filed a U.S. return, received an IRS notice, or simply want to make sure your annual filings are correct, Johri CPA has the expertise to handle it. Book a free 20-minute consultation and we will give you a clear picture of where you stand, at no cost and with no commitment.

Woodbridge: 905-605-5272
Brampton: 905-230-0115

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