Canada & US

Canadian and US tax forms, side by side.

Moving south, moving home, or earning on both sides of the border? Here's how the forms and terms line up, so you know what to look for and what to bring.

The basics

What it isCanadaUnited States
Tax agencyCanada Revenue Agency (CRA)Internal Revenue Service (IRS)Texas has no state income tax. Most provinces collect provincial tax on the same CRA return (Quebec files its own).
Personal tax numberSocial Insurance Number (SIN)Social Security Number (SSN), or ITIN if you can't get an SSN
Business numberBusiness Number (BN)Employer Identification Number (EIN)
Personal tax returnT1 returnForm 1040 (Form 1040-NR for non-residents)
Filing deadlineApril 30 (June 15 if self-employed, but any balance is still due April 30)April 15 (Form 4868 extends the filing date to Oct 15, not the payment date)
CouplesEach spouse or common-law partner files their own returnMarried couples can file one joint returnCommon-law partners have no US equivalent; unmarried partners file separately.
After you fileNotice of Assessment (NOA)No automatic notice; you can request an IRS transcript
Online accountCRA My AccountIRS Online Account

Income slips

What it isCanadaUnited States
Employment incomeT4W-2
Contract / self-employed incomeT4A (box 048)1099-NEC
Interest and dividendsT51099-INT / 1099-DIV
Selling investmentsT50081099-B
Trust or partnership incomeT3 / T5013Schedule K-1
Government pensionT4A(P) for CPP, T4A(OAS) for Old Age SecuritySSA-1099 for Social Security
Retirement plan withdrawalsT4RSP / T4RIF1099-R
Unemployment benefitsT4E (Employment Insurance)1099-G
Income paid to a non-residentNR41042-S

Savings and retirement

What it isCanadaUnited States
Main retirement savings planRRSP401(k) or Traditional IRAUnder the tax treaty, RRSP growth can stay tax-deferred in the US.
Tax-free savingsTFSARoth IRA (closest match)The US does not treat a TFSA as tax-free. US residents usually report the income.
Education savingsRESP529 planThe US does not treat an RESP as tax-sheltered.
Contribution slipRRSP contribution receiptForm 5498 (IRA contributions)
Public pensionCPP / QPP and OASSocial Security

Self-employed and business

What it isCanadaUnited States
Self-employment incomeForm T2125Schedule C, plus Schedule SE for self-employment tax
Corporation returnT2Form 1120 (C corp) or 1120-S (S corp)
Sales taxGST/HST, filed with the CRAState and local sales tax (Texas Comptroller); no federal sales tax
Payroll reportingPayroll remittances and T4 slipsForm 941 (quarterly), Form 940, W-2 and W-3
Paying tax during the yearInstalment paymentsEstimated tax payments (Form 1040-ES)
DepreciationCapital cost allowance (CCA)Depreciation (MACRS, Section 179)

Common terms

What it isCanadaUnited States
Main personal amountBasic personal amount (a credit)Standard deduction
Income figure used for creditsNet income (line 23600)Adjusted gross income (AGI)
Child benefitsCanada Child Benefit (CCB)Child Tax Credit
Selling your homePrincipal residence exemptionHome sale exclusion (up to $250,000, or $500,000 for married couples)
Medical costsMedical expense tax creditItemized medical deduction (costs above 7.5% of AGI)
Charitable givingOfficial donation receiptWritten acknowledgment from the charity (for gifts of $250+)

Cross-border forms

What it isCanadaUnited States
Foreign accounts and propertyForm T1135 (foreign property costing over C$100,000)FBAR (FinCEN 114) if foreign accounts total over US$10,000; Form 8938 at higher amounts
Foreign tax creditForm T2209Form 1116
Claiming treaty benefitsCanada-US tax treatyForm 8833 (treaty position), W-8BEN (given to US payers)
Snowbirds spending winters in the USStill a Canadian residentForm 8840 (closer connection) to avoid being treated as a US resident
Year you moveDeparture return (deemed sale of some assets)Dual-status return may applyTalk to James before you move. Timing matters.

Good to know: this is a general guide to help you find your way around the paperwork. It isn't tax advice, and rules and amounts change. Every situation is different, so ask James before making decisions, especially in the year you move.