Nine US offices  /  every state and province served(360) 862-6556
Clarity Cross BorderBook a call

Home  /  Services  /  Cross-border tax planning

Every number on a return was decided months before the return existed.

Cross-border tax planning is the work that happens while the choices are still open: before the move, before the sale, before the option vests. It changes outcomes rather than reporting them.

The distinction

Planning and compliance are not the same purchase

Preparation answers a question that has already been settled. Planning decides the answer.

A cross-border tax accountant preparing your return works with facts that are fixed. The residency dates are what they are. The disposal happened when it happened. Applying the rules correctly and claiming every available relief is real work, and it has a ceiling.

Planning has no ceiling, because it operates on the facts themselves rather than on their treatment.

In a domestic tax life that difference is modest. Across a border it is enormous, because two systems are each applying their own rules to the same event and the interaction between them is often the largest single variable in the calculation.

The uncomfortable consequence is that the value of this service falls the longer you wait, and reaches zero on a date you can usually see coming.

Working through a tax return at a laptop
The whole argument
Advice in March about last year is bookkeeping. Advice in March about next year is planning.

We would rather be the second. It is more useful to you, and it is the only version of this work where the fee is small relative to what it moves.

When cross-border tax planning pays for itself

Five moments where a conversation beforehand routinely saves multiples of the fee. All five have a date attached, and all five are visible in advance.

Before a move

Residency and departure

Model the departure charge, the arrival year rates, and which assets to sell on which side of the line.

Before a sale

Property and investments

Principal residence relief, withholding, clearance certificates, and the gain split across two systems.

Before vesting

Equity compensation

Options and RSUs are sourced across the period earned, not the day they vest, and a move splits them.

Before retirement

Pensions and plans

The order in which RRSPs, 401ks, IRAs and social security are drawn changes the lifetime number materially.

Before incorporating

Entity and structure

Entity choice made before advice is the most expensive avoidable mistake in cross-border business.

Before, not afterThe largest levers close on the departure date, the completion date or the vesting date
Modelled in figuresTwo or three scenarios costed side by side, so you choose between outcomes
Fixed feeQuoted once the scope is clear, and we will tell you if the work is not worth commissioning

Planning work we are asked for most

Roughly in order of how often it comes up.

Individuals

  • Pre departure and pre arrival modelling
  • Residency date and tie planning
  • Day count strategy for frequent crossers
  • Equity compensation timing
  • Property disposal timing
  • Currency and remittance planning

Retirement

  • RRSP and RRIF withdrawal sequencing
  • 401k, IRA and Roth treatment across the border
  • Pension and social security coordination
  • Treaty elections on registered plans
  • Drawdown order across two systems
  • Residency choice in retirement

Owners

  • Entity selection before formation
  • Owner compensation, salary against dividend
  • Permanent establishment avoidance
  • Transfer pricing set up
  • Repatriating profit across the border
  • Exit and sale planning

Three decisions people make without advice

Each is routine, reversible only at cost, and made every week by people who did not know there was a decision to make.

01

Selling the house on the wrong side of the move

Residency at the moment of sale changes the withholding and clearance requirements, but it is not the whole answer. Substantive relief also depends on ownership, use, designation and qualifying residency years, so selling after a move does not automatically remove US section 121 or Canadian principal residence relief. The ownership and occupancy history matters as much as the sale date, and timing can still move the number materially.

02

Letting the entity choice precede the advice

Structures get formed because a lawyer or an online service suggested one, and the tax consequences surface at the first filing. Unwinding costs several multiples of the initial conversation.

03

Drawing retirement income in the obvious order

Taking from the nearest account first is intuitive and frequently wrong. Sequencing registered plans against taxable accounts across two systems is among the highest value modelling available to anyone in this position.

Questions about planning engagements

This is general guidance rather than advice on your situation.

How far ahead do we need to talk?

For a move, ideally the tax year before. For a sale or a vesting event, a few months. For retirement drawdown, several years, because the sequencing decisions compound. A late conversation is still worth having, it simply has fewer levers left in it.

What does it cost compared with a return?

More than a return and considerably less than the exposure it usually addresses. It is quoted as a fixed fee once the scope is clear, and the first call is free precisely so we can tell you whether the work is worth commissioning at all.

Will you tell me if I do not need it?

Yes, and it happens often. Plenty of cross-border situations are simple enough that good preparation is the whole job.

Can you plan around a move that already happened?

Partly. Some elections remain available in the arrival year and some positions can still be taken. But the largest levers close on the departure date, which is why this page exists.

Where planning usually starts

These four situations account for most planning enquiries.

Talk to us while the choices are still open.

Twenty minutes, no charge. We will tell you whether planning is worth commissioning in your case.

Book a call