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 is | Canada | United States |
|---|---|---|
| Tax agency | Canada 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 number | Social Insurance Number (SIN) | Social Security Number (SSN), or ITIN if you can't get an SSN |
| Business number | Business Number (BN) | Employer Identification Number (EIN) |
| Personal tax return | T1 return | Form 1040 (Form 1040-NR for non-residents) |
| Filing deadline | April 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) |
| Couples | Each spouse or common-law partner files their own return | Married couples can file one joint returnCommon-law partners have no US equivalent; unmarried partners file separately. |
| After you file | Notice of Assessment (NOA) | No automatic notice; you can request an IRS transcript |
| Online account | CRA My Account | IRS Online Account |
Income slips
| What it is | Canada | United States |
|---|---|---|
| Employment income | T4 | W-2 |
| Contract / self-employed income | T4A (box 048) | 1099-NEC |
| Interest and dividends | T5 | 1099-INT / 1099-DIV |
| Selling investments | T5008 | 1099-B |
| Trust or partnership income | T3 / T5013 | Schedule K-1 |
| Government pension | T4A(P) for CPP, T4A(OAS) for Old Age Security | SSA-1099 for Social Security |
| Retirement plan withdrawals | T4RSP / T4RIF | 1099-R |
| Unemployment benefits | T4E (Employment Insurance) | 1099-G |
| Income paid to a non-resident | NR4 | 1042-S |
Savings and retirement
| What it is | Canada | United States |
|---|---|---|
| Main retirement savings plan | RRSP | 401(k) or Traditional IRAUnder the tax treaty, RRSP growth can stay tax-deferred in the US. |
| Tax-free savings | TFSA | Roth IRA (closest match)The US does not treat a TFSA as tax-free. US residents usually report the income. |
| Education savings | RESP | 529 planThe US does not treat an RESP as tax-sheltered. |
| Contribution slip | RRSP contribution receipt | Form 5498 (IRA contributions) |
| Public pension | CPP / QPP and OAS | Social Security |
Self-employed and business
| What it is | Canada | United States |
|---|---|---|
| Self-employment income | Form T2125 | Schedule C, plus Schedule SE for self-employment tax |
| Corporation return | T2 | Form 1120 (C corp) or 1120-S (S corp) |
| Sales tax | GST/HST, filed with the CRA | State and local sales tax (Texas Comptroller); no federal sales tax |
| Payroll reporting | Payroll remittances and T4 slips | Form 941 (quarterly), Form 940, W-2 and W-3 |
| Paying tax during the year | Instalment payments | Estimated tax payments (Form 1040-ES) |
| Depreciation | Capital cost allowance (CCA) | Depreciation (MACRS, Section 179) |
Common terms
| What it is | Canada | United States |
|---|---|---|
| Main personal amount | Basic personal amount (a credit) | Standard deduction |
| Income figure used for credits | Net income (line 23600) | Adjusted gross income (AGI) |
| Child benefits | Canada Child Benefit (CCB) | Child Tax Credit |
| Selling your home | Principal residence exemption | Home sale exclusion (up to $250,000, or $500,000 for married couples) |
| Medical costs | Medical expense tax credit | Itemized medical deduction (costs above 7.5% of AGI) |
| Charitable giving | Official donation receipt | Written acknowledgment from the charity (for gifts of $250+) |
Cross-border forms
| What it is | Canada | United States |
|---|---|---|
| Foreign accounts and property | Form 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 credit | Form T2209 | Form 1116 |
| Claiming treaty benefits | Canada-US tax treaty | Form 8833 (treaty position), W-8BEN (given to US payers) |
| Snowbirds spending winters in the US | Still a Canadian resident | Form 8840 (closer connection) to avoid being treated as a US resident |
| Year you move | Departure 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.