India-Canada-USA Cross-Border Tax Guides
Treaties, moving checklists, foreign account reporting, retirement accounts, estates and family planning for people whose lives and money cross India, Canada and the USA.
Most tax guidance is written from inside one country. That is not how many families and businesses actually live: an Indian-born engineer on a U.S. visa with parents in Pune and a sibling in Mississauga, a Canadian citizen who moves to Illinois for a job and keeps an RRSP, an owner with companies in two countries. The hardest questions sit between systems: who taxes first, which account is reported where, which treaty applies and what each side calls the same thing.
These guides take the corridors one at a time (U.S.-Canada, U.S.-India, Canada-India) and then the three-country questions. They explain treaties in practical terms, give moving checklists for each direction, compare foreign account reporting and tax credits across the three systems and show how retirement accounts, gifts and estates are treated on each side.
We are a U.S. CPA firm. We handle the U.S. side and coordinate with your Canadian accountant and your Indian Chartered Accountant. Start with the residency tie-breaker guide if you are not sure where you are resident, then use the side-by-side comparisons for quick lookups.
United States and Canada
Treaty, citizens and residents on each side, snowbirds, RRSP and TFSA, social security and real estate.
US Canada Tax Treaty Guide: Residency, Pensions, Credits and Forms
How the Canada-United States convention allocates taxing rights, settles dual residency and what to file to claim it.
Read USCAUS Citizens Living in Canada: Filing Both Returns, Credits and Reporting
Step-by-step guide for Americans resident in Canada covering both returns, foreign tax credits, account reporting and Canadian investments.
Read USCACanadians Living in the US: Residency, TN and H-1B Moves, RRSPs and Filing
How Canadians moving to the US end Canadian residency, start US residency and handle RRSPs and accounts.
Read USCAForm 8840 for Canadian Snowbirds: Closer Connection Exception Steps
How Canadian winter visitors count US days, claim the closer connection exception and keep Canadian filings consistent.
Read USCARRSP US Tax Treatment: RRIF, TFSA and RESP Rules for US Persons
How Americans and US residents report Canadian RRSPs, RRIFs, TFSAs and RESPs, and what replaced Form 8891.
Read USCACanadian Mutual Funds PFIC Rules: ETFs, Form 8621 and Your Options
Why most Canadian mutual funds and ETFs are PFICs for US taxpayers, and which elections help.
Read USCACross-Border Remote Work US Canada: Tax, Payroll and Treaty Rules
Tax, payroll and social security rules when you or your employer work remotely across the US-Canada border.
Read USCAUS Canada Totalization Agreement: Social Security, CPP and Certificates
How the US-Canada social security agreement assigns coverage, combines credits for pensions and what certificates of coverage do.
Read USCACanadian-Owned US Real Estate: Estate Tax, FIRPTA and Rental Income
What Canadians owning US homes or condos must know about estate tax, treaty credits and sale withholding.
ReadUnited States and India
Treaty, India income and assets, remittances, moving checklists, business and succession.
US India Tax Treaty Explained: What It Protects and Where U.S. Tax Still Applies
What the 1989 US India tax treaty gives H-1B, green card and NRI families, and its limits.
Read USINHow to Report India Income and Assets on a U.S. Tax Return
Which Indian income and assets U.S. taxpayers must report, on which forms, and how India finds out.
Read USINSend Money from India to the USA: LRS, Gifts, Form 3520 and Tax Rules
LRS limits, Indian paperwork and U.S. gift reporting for family money moving from India to the U.S.
Read USINMoving from India to the US Tax Checklist: Before, During and After Arrival
A dated checklist for Indians relocating to the U.S.: Indian status, bank accounts, the arrival-year return, foreign reports.
Read USINMoving from the US to India Tax Checklist: Dual-Status Year, RNOR and NRI Accounts
Leaving the U.S. for India: final U.S. return, residency end date, RNOR planning, bank accounts and disclosures.
Read USINUS India Business Structure for Trade: LLC, C Corp, Private Limited or LLP
Choosing between a U.S. LLC, C corporation, Indian private limited company or LLP for India-U.S. trade.
Read USINUS India Estate Planning: Wills, Estate Tax, Inheritance and Succession
How U.S. estate tax, Indian succession, wills and heir reporting interact for families with assets in both countries.
ReadCanada and India
Treaty, moving checklists, T1135 and Indian assets, trade structures and students.
India Canada Tax Treaty Guide: Residency, Pensions and Withholding Rates
How the India-Canada tax agreement settles residency, caps withholding and relieves double tax, and how to claim it.
Read INCAMoving From India to Canada Tax Checklist: Steps for Newcomers and NRIs
Tax checklist for moving from India to Canada: Indian residency, bank accounts, arrival-day values and Canadian reporting.
Read INCAMoving From Canada to India Tax Checklist: Departure Tax, RNOR and Accounts
Step-by-step tax checklist for returning from Canada to India, covering departure tax, registered accounts, RNOR status and disclosure.
Read INCAT1135 for India Assets: How Canadian Residents Report Indian Property
Which Indian accounts, investments and property Canadian residents report on Form T1135, and how to file.
Read INCAIndia Canada Business Structures for Trade: Subsidiary, Branch or Direct Sales
How to choose between direct trade, a subsidiary and a branch when doing business between India and Canada.
Read INCAIndian Students in Canada Taxes: Study Permit, Tuition Credits and Remittances
CRA filing, tuition credits and India's education remittance rules for Indian students in Canada and their families.
ReadAll three countries
Residency tie-breakers, reporting, foreign tax credits, family, retirement and estates.
Residency Tie-Breaker Rules for India, Canada and the US Compared
How the three bilateral treaties decide residence when India, Canada and the U.S. each claim you.
Read USCAINFBAR vs T1135 vs Schedule FA: Foreign Account and Asset Reporting Compared
A table comparing U.S., Canadian and Indian foreign asset reports so three-country families file the right ones.
Read USCAINForeign Tax Credit for US, Canada and India: How Each Country Gives Relief
Compare Form 1116, Canada's credit and India's Form 67 so tax paid in one country is not wasted.
Read USCAINCross-Border Family Tax Planning for India, Canada and USA Households
A practical map for families with members in India, Canada and the U.S.: filings, accounts, gifts and deadlines.
Read USCAIN401k vs RRSP vs EPF: Cross-Border Retirement Planning in Three Countries
How a 401(k), a Canadian RRSP and an Indian EPF or NPS fit together for cross-border families.
Read USCAINGift and Estate Tax Compared: US, Canada and India Side by Side
Who pays tax on gifts and inheritances in the U.S., Canada and India, and which forms follow.
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