Whether you're a US citizen living in Canada or a Canadian working or investing in the US, KPMG's private client-cross border tax professionals can help you successfully navigate the tax laws of both nations.

A complex landscape

American citizens and green card holders who live in Canada face daunting challenges in cross border tax planning since they must comply with American and Canadian tax laws. In addition, Canadians (and other non-Americans) who invest in US properties, spend a significant amount of time in the US either working or on vacation, or those who want to move to the US often find they're facing a similar set of tax hurdles.

Individuals in these situations are confronted by a complex tax landscape that can become even more complicated as tax laws on either side of the border continue to evolve. This is a particularly difficult problem for those who have investments abroad, or who have established a cross border business. Tax reporting and corporate structuring issues should also be considered, since taxpayers could face substantial non-compliance penalties even in cases where no significant tax exposure exists.

The list of cross border tax issues is long and, as mentioned, is getting longer as key issues arise in the areas of charitable giving, private foundations, partnerships, immigration, residency planning and US expatriation, just to name a few. Fortunately, individuals with international connections can turn to KPMG's private client services for trusted, reliable and experienced cross-border tax advice. KPMG takes a personalized approach to cross border tax preparation, and our private client services specialize in all types of cross border tax issues.

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Trust planning

Cross border estate planning, wills and trusts can provide both taxable and non-taxable benefits to the estate and its beneficiaries. Problems can arise, however, when a trust exists on one side of the Canada-US border and a beneficiary or contributor resides on the other. Conflicting cross border tax issues can be frustrating and can in some cases lead to accidental non-compliance.

KPMG provides private client services that take into account the complexities of international trust and estate planning. For example, we can assist you in designing a will with testamentary trust provisions that qualifies for both US estate tax deferral mechanisms and the Canadian capital gains deferral for assets passing to a surviving spouse. This is just one of many ways we can work with you to develop a tax-effective approach to international trust and estate planning that can enhance wealth management during your lifetime and beyond.

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Tax compliance

International tax is getting more complex and the continually evolving US-Canada economic relationship complicates the cross border tax landscape even further. The effects may include cross border tax compliance issues and corporate structuring questions regarding tax planning, and may affect how individuals prepare for future challenges, changes and opportunities in their international business activities.

KPMG's cross border tax services professionals bring an extensive understanding of US and international tax matters to bear on tax compliance issues. Our deep industry knowledge can provide you with cross border tax advice that goes beyond simple tax compliance. No matter what type of current tax exposure you're dealing with, we can offer practical solutions to help you manage cross border tax compliance, personal tax planning, tax filing and information reporting requirements in the countries where you reside, hold citizenship, own assets or conduct business.

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Estate planning

Canada and the US both impose significant taxes on the transfer of wealth. In addition, Canadians who own marketable securities or real property in the US, or who have a US pension, must consider the US income tax implications of cross border estate planning. A carefully considered cross border estate planning strategy can help manage the various taxes imposed by multiple jurisdictions while mitigating emotional stress and distress.

KPMG's experienced tax consultants can assess an individual's exposure to capital gains, estate, inheritance, gift, and probate taxes, and analyze alternatives for you as you consider how to distribute your wealth to heirs, charities, and other beneficiaries. We have the tools to help you approach, understand and resolve cross border estate planning challenges and other international trust and estate planning issues. Our professionals can assist in the design and implementation of a wide-ranging estate plan that accomplishes your wealth-transfer intentions while managing exposure to foreign taxation.

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Cross-border income tax and transaction planning

Cross border income tax issues can be confusing to say the least – and confounding for those dealing with cross border tax preparation. Unfortunately, cross border tax issues are a fact of life for individuals, organizations and businesses with interests and investments that span the US-Canada border. KPMG can help you implement a customized tax plan that can be reviewed and updated regularly. We constantly track legislative developments in the tax arena – both in the US and in Canada – in order to identify new opportunities and avoid adverse outcomes.

With our deep experience in cross border tax consulting, KPMG can help you meet your investment and earnings objectives while managing your obligations in multiple jurisdictions. Our experienced and dedicated professionals can assist you with corporate structuring issues, resolve tax issues over vacation properties, and provide tax-efficient retirement, trust and estate planning services.

Canadians – Manage your US estate tax exposure

An overview of US estate tax and highlights important considerations to keep in mind when revisiting your estate plan

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What to know before you go

Tax costs for spending time in the US

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Frequently asked questions (FAQs)

KPMG is an industry leader in the field of cross border tax consulting and international trust and estate planning. Our private client services teams offer meaningful advice on cross-border tax issues, providing clients with a complete and multi-disciplined perspective on cross border tax matters.

International investors, property owners and business can feel overwhelmed by the complexity of cross border tax issues. It's really no mystery: two countries with very different – and at times conflicting – tax systems can present individuals with a host of challenges related to tax accounting, filing, compliance and more. KPMG brings an extensive understanding of cross border tax issues and provides effective cross border tax advice to help you resolve what seem to be insurmountable issues.

The US and Canada both employ different tax systems and the rules and regulations regarding cross border tax compliance vary widely between these neighbouring nations. What's more, each country continually enacts, amends and repeals tax-related regulations regardless of any potential conflicts individuals, organizations and businesses may experience as a result. KPMG's knowledgeable cross border tax consulting professionals keep up with changing American and Canadian tax policies so you don't have to.

Cross border estate planning and estate planning for wills and trusts are governed by the tax codes of both the US and Canada – and conflicts frequently occur. Well-meaning taxpayers can experience issues when following one nation's regulations results in accidental noncompliance with those of the other. KPMG in Canada's cross border estate planning services, estate planning wills and trusts advisors, and international trust and estate planning professionals will assist you in resolving these and other cross border tax matters.

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