New talk: Cross Border Taxation

This week I gave a talk called “US/Canada Cross Border Taxation”.

This talk is an overview of US and Canadian international income tax law for individuals in cross-border situations, including:

  • Canadians in the US, or recently moved / considering moving to or from the US
  • Americans in Canada and tax consequences of US citizenship
  • transferring internationally with Google stock grants
  • cross-border investments and retirement savings (401(k), RRSP, etc)
  • structure and sources of tax law in Canada and the US
  • features of the US-Canada tax treaty
  • foreign asset reporting (T1135, FBAR, etc)

You can watch a video of the talk here, or look at the slides at


Inspired by discussions with coworkers, I created an RRSP FAQ (Google Docs link).

The FAQ began life as an internal document, but most of it had broader applicability, so I thought I would share it with the world. (The public version excises or anonymizes details that were specific to my employer’s benefits.)

Effectively Complicated Income

I ended my post on 60(j) rollovers with a cliffhanger, by hinting that the rate of US tax on a nonresident alien’s IRA or 401(k) distribution might depend on the extent to which the income is “effectively connected with the conduct of a trade or business within the United States”—a term of art from IRC § 871 that I quoted without the elaboration it deserves.

Continue reading Effectively Complicated Income

The advance refund is not an advance refund

Pandemic tax relief encompasses far more than deadline pushes; governments are also writing checks. The US, under the CARES Act[1]Coronavirus Aid, Relief, and Economic Security Act, Pub. L. 116-136, 134 Stat. 281 (2020), is giving many of its citizens and residents a $1200 payment. The IRS calls this an “Economic Impact Payment” (EIP), but the codification in IRC § 6428 calls it an “advance refund amount”[2]IRC § 6428(f).

Continue reading The advance refund is not an advance refund

1 Coronavirus Aid, Relief, and Economic Security Act, Pub. L. 116-136, 134 Stat. 281 (2020)
2 IRC § 6428(f)