Requirements and Considerations for U.S. Citizens or Green Card Holders
If you are a U.S. citizen or Green Card holder living in Canada, you are subject to U.S. tax rules regardless of where you reside. The U.S. taxes its citizens and permanent residents on worldwide income, meaning you must file an annual U.S. tax return even if you pay tax in Canada.
In addition to filing Form 1040, you may be required to report non-U.S. bank accounts and certain other foreign financial assets to the U.S. government through forms such as the FBAR (FinCEN 114) and Form 8938. Failing to file these forms can result in significant penalties.
The Canada–U.S. Tax Treaty helps prevent double taxation by allowing foreign tax credits and coordinating certain rules, but careful planning is still required to optimize your tax position. Special considerations may also apply for retirement accounts, investments, and estate planning, as these can be treated differently under Canadian and U.S. laws.
Green Card holders should also be aware of potential exit tax implications if they relinquish their status, and both groups must consider how U.S. estate and gift tax rules apply to their situation.
Please visit our Requirements and Considerations for U.S. Citizens section for more information.
Please contact us if you would like to review your cross-border tax obligations and develop strategies that keep you compliant while minimizing your overall tax burden.