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
Note: CLE credit is not offered on this program
Recording of a 110-minute CPE webinar with Q&A
This webinar will provide tax advisers with a thorough and practical guide into 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 useful information on tax reporting of cross-border trust ownership.
Outline
- U.S.-Canada tax treaty overview and dual tax mitigation provisions
- Treatment of U.S.-based LLCs and pass-through entities in cross-border situations
- Passive and unearned income treatment
- U.S. tax reporting requirements of Canadian-sourced investments
- Limitation of benefit provisions
Benefits
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
- U.S. reporting requirements of Canadian-sourced investment
Faculty

Jessica Blazejewicz, CPA, CA
Senior Manager, International Tax
BDO Canada
Ms. Blazejewicz, CPA, CA is a senior manager with the international tax services group of BDO Canada LLP. With over 14... | Read More
Ms. Blazejewicz, CPA, CA is a senior manager with the international tax services group of BDO Canada LLP. With over 14 years of tax experience, she advises clients on both Canadian inbound and outbound tax matters, including cross-border financing, structuring, acquisitions and divestitures across a variety of sectors including mining, technology and financial services. Prior to Ms. Blazejewicz's foray into international taxation almost a decade ago, she advised Canadian and foreign-owned multinational corporations, individuals and partnerships with respect to Canadian domestic tax matters.
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C. Edward Kennedy, Jr., CPA, JD
Managing Director
C Edward Kennedy Jr
Mr. Kennedy has more than 36 years of experience dealing with a variety of international tax matters, specializing in... | Read More
Mr. Kennedy has more than 36 years of experience dealing with a variety of international tax matters, specializing in tax consulting services to a wide variety of clients ranging from closely held companies to multi-national businesses. His expertise includes domestic and foreign income and social security tax planning, tax compliance for individuals and corporations, tax treatment of incentive compensation plans, international assignment program administration, and international assignment policy design. He has also served as the U.S. practice leader for international social security matters for a Big 4 accounting firm.
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