);
+1 (902) 468 3066 dbb@burnsidelaw.net
Lawyer / Barrister / Solicitor

International Tax Law

Cross-border tax obligations spanning the Canadian, American, and international regimes, for the people and companies who live and do business on both sides of the line.

Scope of work

  • Canada-U.S. tax treaty planning & relief
  • U.S. citizens & green-card holders in Canada
  • Dual-filer compliance (CRA and IRS)
  • Foreign reporting — T1135, FBAR, FATCA
  • Common Reporting Standard (CRS) exposure
  • Non-resident withholding & departure tax
  • Cross-border estates & transfer pricing

Few areas of tax create as much avoidable anxiety as cross-border exposure. A Canadian resident with U.S. assets, a U.S. citizen living in Nova Scotia, a snowbird, a company expanding south, an estate with beneficiaries in two countries: each faces overlapping obligations to two revenue authorities at once, and the rules are not designed to be intuitive.

The Canada-United States Tax Convention exists precisely to prevent the same income from being taxed twice and to allocate taxing rights between the two countries. Used properly, the treaty is a shield; ignored, it becomes a trap. We advise on treaty residence and tie-breaker rules, foreign tax credits, and the elections that determine which country taxes what, and in what order.

Compliance is where most cross-border problems are born. U.S. persons in Canada generally must file with the IRS regardless of where they live, including foreign account reporting under FBAR and the Foreign Account Tax Compliance Act (FATCA); Canadian residents with foreign property must file the CRA’s Form T1135; and the global Common Reporting Standard means financial information now moves automatically between tax authorities. We help clients become and stay compliant, address historical gaps through the appropriate disclosure channels in each country, and plan for events such as emigration, a sale, or an inheritance that trigger departure tax, non-resident withholding, or estate-tax exposure.

This is the practice where the firm’s dual-jurisdiction footing matters most. Barrister and Solicitor Derek Brett holds bar admissions in both nations and arrived in Nova Scotia from the United States; the cross-border tax picture is read here with a working knowledge of how each system actually operates, rather than from one side of the border looking across.