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 course 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 helpful 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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Steven Flynn, CPA, CA, CPA (Washington)
Partner
Andersen
Mr. Flynn concentrates in the area of Canadian and US cross-border tax. His practice includes US and Canadian... | Read More
Mr. Flynn concentrates in the area of Canadian and US cross-border tax. His practice includes US and Canadian income tax planning and compliance for both individuals and businesses. He provides income tax advice on US investment and operations in Canada, Canadian investment and operations in the US, investment in US and Canadian real property, employee or individual emigration and/or temporary relocation and the Canada-US Income Tax Treaty.
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Marc J. Gedeon, Esq., CPA, CA
Founder & President
Gedeon Law & CPA
Mr. Gedeon is a lawyer and certified public accountant who has nearly 15 years of combined experience advising clients... | Read More
Mr. Gedeon is a lawyer and certified public accountant who has nearly 15 years of combined experience advising clients on tax, legal, and business related matters. He provides tax and accounting services to individuals, corporations, LLCs, partnerships and S Corporations. In his legal practice, Mr. Gedeon represents clients in matters related to business law, estate planning, employment law and real estate transactions.
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CPE credit is not available on downloads.
CPE On-Demand