This module introduces Canadian CPA professionals to the core structure, jurisdictional reach, and compliance landscape of the U.S. federal income tax system, specifically as it applies to Canadians with U.S. connections. With a strong emphasis on domestic U.S. tax law (not treaty-based relief), the module covers essential topics such as the Substantial Presence Test, U.S. source income rules, and estate tax exposure for Canadian individuals. CPA participants will gain fluency in the key distinctions between Fixed, Determinable, Annual or Periodic (FDAP) income and effectively connected income with a U.S. trade or business (ETBUS), and understand the withholding and filing implications under each. The course also addresses complex scenarios involving Canadian corporations with U.S. operations, the use of hybrid entities such as LLCs and LPs, and the circumstances under which Form 1120-F and other disclosures may be triggered. Extensive coverage is given to U.S. reporting obligations—including Forms 5471, 8865, 8938, and the FBAR—and the severe civil and criminal penalties for non-compliance. The module concludes with estate and gift tax considerations for Canadians owning U.S. situs property, along with strategic planning tools and compliance best practices. By the end of this module, CPA professionals will be better equipped to identify U.S. tax exposure for their Canadian clients and integrate U.S. compliance into holistic cross-border tax planning.
This module introduces Canadian CPA professionals to the core structure, jurisdictional reach, and compliance landscape of the U.S. federal income tax system, specifically as it applies to Canadians with U.S. connections. With a strong emphasis on domestic U.S. tax law (not treaty-based relief), the module covers essential topics such as the Substantial Presence Test, U.S. source income rules, and estate tax exposure for Canadian individuals. CPA participants will gain fluency in the key distinctions between Fixed, Determinable, Annual or Periodic (FDAP) income and effectively connected income with a U.S. trade or business (ETBUS), and understand the withholding and filing implications under each. The course also addresses complex scenarios involving Canadian corporations with U.S. operations, the use of hybrid entities such as LLCs and LPs, and the circumstances under which Form 1120-F and other disclosures may be triggered. Extensive coverage is given to U.S. reporting obligations—including Forms 5471, 8865, 8938, and the FBAR—and the severe civil and criminal penalties for non-compliance. The module concludes with estate and gift tax considerations for Canadians owning U.S. situs property, along with strategic planning tools and compliance best practices. By the end of this module, CPA professionals will be better equipped to identify U.S. tax exposure for their Canadian clients and integrate U.S. compliance into holistic cross-border tax planning.
Comprehensive, structured learning path
2 modules • 8 lessons • 1.3h total
Get unlimited access to this course and 25+ others with your annual membership