US-Canadian Dual Taxation Pitfalls: Reporting Issues and Planning Opportunities for US Taxpayers

Navigating Tax Treaties to Minimize Tax on Passive Income, Retirement Distributions and Pass-Through Income

Recording of a 110-minute CPE webinar with Q&A

Conducted on Wednesday, November 30, 2016

Recorded event now available

or call 1-800-926-7926
Program Materials

This CPE webinar will provide tax advisers with a thorough and practical guide into the tax reporting requirements and planning opportunities for U.S. taxpayers with clients earnings or assets in Canada, as well as Canadian citizens with U.S. tax reporting obligations. The panel will discuss US 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 treatment of pension withholdings and distributions.


The Canada-United States border is the longest contiguous international border on earth. The geographical and demographic similarities between the two countries contribute to the world's largest trade relationship between 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 but, 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 engage in careful planning on both sides of the border. Other areas of concern in U.S.-Canadian tax planning include treatment of passive income and tax considerations of cross-border pension ownership, contributions and withdrawals. Hovering over all these concerns is the extensive U.S. tax reporting requirements imposed on taxpayers with U.S. filing obligations.

Listen as our experienced panel provides comprehensive and practical guidance on navigating U.S.-Canada cross-border tax planning and reporting issues.



  1. U.S.-Canada Tax Treaty Overview and dual-tax mitigation provisions
  2. Treatment of U.S.-based LLCs and pass-through entities in cross-border situations
  3. Passive and un-earned income treatment
  4. U.S. ownership of Canadian RRSPs and other retirement accounts
  5. Limitation of Benefit provisions


The panel will discuss these and other important topics:

  • What are the 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 U.S.-Canada Income Tax Treaty
  • Key risks and challenges of passive/un-earned income in cross-border situations
  • Tax treatment of U.S. taxpayers’ ownership of Canadian RRSPs and other retirement plans


Gilmour, Grant
Grant Gilmour

International Tax Partner
Gilmour Group CPAs

Mr. Gilmour is a corporate tax advisor. His practice focuses on corporate clients in manufacturing and distribution...  |  Read More

Kennedy-C. Edward
C. Edward Kennedy, Jr., CPA, JD

GrossDukeNelson & Co.

Mr. Kennedy has more than 34 years of experience dealing with a variety of international tax matters, specializing...  |  Read More

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