02 · US & CROSS-BORDER TAX

Both sides of the border. One team.

Advisory and compliance — because qualified US filers are scarce in Canada, we handle both the planning and the filing. Cross-border structuring, treaty analysis, IRS and state filings, and dispute resolution.

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WHAT WE DO

US and cross-border tax services.

Cedar Group's US and cross-border practice handles both sides of the border — advisory and compliance. Unlike the Canadian practice, we do prepare and file US returns, because qualified US filers are scarce in Canada and clients need both the planning and the filing in one place.

Sandy and Bill hold CPA designations in both Canada and the United States, so when a US filing creates a Canadian consequence — or your holdco structure meets US rules — it is handled in the same office.

US Personal Tax Returns

Forms 1040 and 1040-NR for Canadians with US income, US residency, or US filing obligations. Dual-status returns for the year of arrival or departure.

US Corporate Tax Returns

Forms 1120, 1120-F, and 1120-S for Canadian-owned US entities, US branches of Canadian corporations, and US-source business income.

US Partnership & Trust Returns

Forms 1065, K-1 allocations, and Form 1041 for US partnerships and trusts with Canadian-connected partners or beneficiaries.

Foreign Information Reporting

Form 5471 (controlled foreign corporations), Form 5472 (foreign-owned US corporations), Form 8865 (foreign partnerships), and Form 3520/3520-A (foreign trusts). The penalties for non-filing are severe — $10,000 or more per form per year.

W-8BEN & Withholding Certificates

Proper treaty-based withholding certificates for Canadians receiving US-source income. Ensures the correct withholding rate is applied at source.

US-Canada Cross-Border Tax

Tax planning for individuals and businesses operating in both jurisdictions — coordinating Canadian and US obligations to minimize the combined tax burden.

Treaty Benefits

Claiming reduced withholding rates and exemptions under the Canada-US Tax Treaty — on dividends, interest, royalties, pensions, and capital gains.

US LLC Structuring

US LLCs are the default recommendation from US advisors — and they are a tax disaster for Canadians. We structure cross-border entities properly.

FBAR & Form 8938

Foreign account reporting for Canadians with US obligations and Americans with Canadian accounts — FBAR (FinCEN 114) and FATCA (Form 8938) compliance.

Dual Residency

Resolving dual tax residency under the Canada-US Treaty's tie-breaker rules — and structuring affairs to maintain a clear residency position.

Cross-Border Estate Planning

Estate planning for families with assets in both Canada and the US — addressing Canadian deemed disposition, US estate tax exposure, and treaty relief.

FIRPTA

Foreign Investment in Real Property Tax Act compliance — withholding, elections, and planning for Canadians selling US real estate.

State Tax Filings

Multi-state income tax, franchise tax, and information reporting obligations for businesses with US nexus.

LED BY

SSSandy

Sandy Saini

US Tax Principal

CPA, CA, CPA (Illinois)

Sandy leads Cedar Group's US and cross-border tax practice. She is a licensed CPA in both Canada and the U.S., with extensive experience in cross-border and inbound U.S. tax.

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Also led by Bill Yang, US Personal & Estate Tax Principal (CPA, CA, CPA Illinois) — leading personal US–Canada cross-border and cross-border estate tax alongside Sandy’s corporate practice.

CASE STUDIES

What recent US & Cross-Border Tax engagements look like.

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Real Estate

The Siblings with Eight Properties — and One Moving to Dubai

Two siblings held eight investment properties worth over $7 million through a single Canadian corporation. One sibling was planning to leave Canada for the UAE. If they did nothing, the corporation would lose its status as a Canadian-controlled private corporation when the Canadian-resident sibling departed — eliminating access to the refundable tax mechanism that allows corporate tax to be partially recovered when dividends are paid out.

RESULT

Effective tax rate reduced from 30%+ to ~22.5%. Over $500,000 in additional after-tax value preserved.

Technology

The Canadian Founder with a US LLC That Became a Tax Nightmare

A Canadian tech founder incorporated a US LLC on the advice of his American lawyer. The LLC was intended to hold US client contracts and simplify US banking. What nobody told him: a US LLC is a "disregarded entity" for US tax purposes — meaning all income flows through to the owner's personal US return. But for Canadian purposes, the LLC is a foreign corporation. The result: the same income was being taxed twice — once in the US (as flow-through income) and once in Canada (as foreign accrual property income), with imperfect foreign tax credit relief.

RESULT

Double taxation eliminated. Ongoing structure aligned across both jurisdictions. Future foreign tax credit claims optimized.

Private Wealth

The Snowbird Who Forgot About Form T1135 — and the IRS

A retired Canadian couple owned a vacation condo in Florida they had purchased in 2016 for $450,000 USD. They never rented it out and assumed it was "just personal use — nothing to report." For nine years, they had not filed Form T1135 (Foreign Income Verification Statement) with the CRA, and they had never considered whether they had US filing obligations.

RESULT

T1135 penalties reduced through VDP. FIRPTA withholding cut to actual tax owed. Capital gain properly reported in both countries with full foreign tax credit.

WHAT CLIENTS SAY

★★★★★GOOGLE

“Sandy provided excellent support on a U.S. tax matter. She was responsive, knowledgeable, and delivered thorough work on a timely basis. She also took the time to answer follow-up questions and make sure everything was clear.”

Nick Singh

Have a situation like this?

Every engagement starts with a no-obligation 15-minute introductory call.

HOW IT WORKS

How a cross-border engagement works.

PHASE I — DISCOVERY & DESIGN

Cross-border work starts with understanding your exposure on both sides. We review your residency status, your corporate structures in both jurisdictions, your income sources, and your filing history. We then model the cross-border tax implications and design a structure that minimizes the combined Canadian and US burden while maintaining compliance in both countries. The Phase I deliverable includes a written recommendation with treaty analysis and a side-by-side comparison of your current and proposed positions.

PHASE II — IMPLEMENTATION

Implementation covers entity restructuring, treaty election filings, IRS and CRA compliance, and coordination between our Canadian and US tax teams. Because Sandy holds CPA designations in both Canada and Illinois, and Bill Yang (US Personal & Estate Tax Principal) brings the same dual-jurisdiction depth, the entire engagement is handled in-house — no referral to a separate US firm.

Strategy Memo· Phase I Deliverable

DRAFTCedar Group

CURRENT STRUCTURE

Shareholder

Direct ownership

HoldCo

Single class

OpCo

All assets · all risk

PHASE I

PROPOSED STRUCTURE

Shareholder

Freeze shares

NEW

Family Trust

Future growth

HoldCo

Capital protection

NEW

OpCo · NewCo

Risk segregated

INCLUDESCost-benefit analysis·Tax modelling·Implementation roadmap

Talk to a cross-border tax advisor.

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