Working for US Employer while having US/Canadian Dual Citizenship - Taxation Questions
I'm a US citizen and I've been offered a really great opportunity that would involve relocating to Canada, and eventually getting Canadian citizenship. The good news is my current US employer is totally fine with me working remotely from Canada! But I'm completely lost when it comes to the tax situation. I understand I'll need to pay income tax to Canada on worldwide income, but I'm also still a US citizen so... do I have to pay taxes twice on the same income? I've heard vaguely about tax treaties and foreign tax credits, but honestly have no clue how any of it actually works in practice. Can someone walk me through exactly how the taxation works with dual citizenship? Like how much should I expect to owe to each country? Will I end up paying way more in taxes overall? Any insight would be super appreciated!
20 comments


Luca Russo
The US-Canada tax treaty helps prevent double taxation, but you'll still have obligations to both countries. Here's how it typically works: As a US citizen, you must file US tax returns regardless of where you live - the US taxes based on citizenship. When living in Canada as a resident, you'll also file Canadian tax returns on your worldwide income. For US taxes, you can use the Foreign Earned Income Exclusion (FEIE) which allows you to exclude up to $120,000 (for 2025) of foreign earned income from US taxation. Alternatively, you can use Foreign Tax Credits to offset US taxes with taxes paid to Canada. Since Canadian tax rates are generally higher than US rates, the tax credits often eliminate most or all US federal tax liability. You'll still need to file FBAR forms if you have foreign accounts totaling over $10,000 at any point during the year. And be aware that some investment accounts like TFSAs (Canadian tax-free savings accounts) aren't recognized as tax-advantaged by the US.
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Nia Wilson
•This is super helpful, thanks! What about retirement accounts? I have a 401k in the US - should I keep contributing to it? And what about starting retirement accounts in Canada once I move there?
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Luca Russo
•For retirement accounts, the tax treaty generally recognizes both countries' primary retirement systems. You can typically continue contributing to your US 401k while in Canada, though it might be more beneficial to consider Canadian options like an RRSP once you establish residency there. For Canadian retirement accounts, RRSPs (Registered Retirement Savings Plans) are recognized under the treaty and can typically be reported as such on your US returns. However, Canadian TFSAs (Tax-Free Savings Accounts) are not recognized as tax-advantaged by the US and may require complex reporting while being subject to US tax on gains.
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Mateo Sanchez
I went through something similar last year and discovered taxr.ai (https://taxr.ai) when I was struggling with all the cross-border tax documentation. It was seriously a game-changer for my situation. I uploaded my US W-2 and my Canadian T4 slips, and it analyzed everything to help identify which credits I could claim in both countries. The tool specifically helped me understand how the foreign tax credits work across the US-Canada tax treaty and prevented me from making a costly mistake with reporting my Canadian investment accounts on my US return.
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Aisha Mahmood
•Did it actually help with figuring out state taxes too? I'm moving from California to Toronto and heard California is especially aggressive about trying to tax you even after you've left.
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Ethan Clark
•I'm considering a similar move but worried about all the extra paperwork. Does this tool actually file the returns for you or just give you information? How does it compare to going to a cross-border tax specialist?
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Mateo Sanchez
•It absolutely helped with state taxes. California is indeed notorious for trying to maintain taxing rights on former residents, but the tool helped me document my permanent move and establish proper Canadian residency to break California tax ties. It provided specific guidance on the necessary documentation to support my non-residency status. The tool doesn't file returns for you - it analyzes your situation and provides detailed guidance. I used that information when working with my accountant, which saved me a ton in consulting fees since I already had everything organized and understood the concepts. For complex cross-border situations like ours, I found it more cost-effective than paying a specialist's hourly rate for the basic analysis work.
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Ethan Clark
Just wanted to update - I tried taxr.ai after seeing this thread and it was incredibly helpful. I've been stressing for months about my upcoming move to Vancouver, especially about tracking which country gets what piece of my investment income. The tool clearly broke down how the tax credits work under the US-Canada treaty and identified specific sections of my investments that would be problematic (like my US municipal bonds that apparently don't get favorable treatment in Canada). Really appreciate the recommendation - saved me from making some pretty big mistakes on my planning!
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AstroAce
When I moved to Canada a few years ago, the most frustrating part was getting any help from the IRS about my specific situation. I spent WEEKS trying to get someone on the phone. Then I found https://claimyr.com which got me through to an actual IRS representative in under 15 minutes when I'd been trying for days before that. You can see how it works here: https://youtu.be/_kiP6q8DX5c. I had specific questions about foreign tax credits that weren't covered in the general publications, and actually talking to someone at the IRS cleared everything up. Totally changed my perspective on dealing with the IRS from abroad.
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Yuki Kobayashi
•How does this even work? The IRS phone lines are always busy when I call, and I'm supposed to believe this service magically gets you through?
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Carmen Vega
•This sounds like a scam. I've never been able to get through to the IRS, especially on international tax matters. I doubt some random service can do what the government itself can't manage.
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AstroAce
•It works by using an automated system that continually calls the IRS using their phone tree navigation until it secures a place in line, then it calls you when it's about to connect with an agent. It's not magic - just clever technology that saves you from having to manually redial and wait on hold for hours. I was skeptical too at first. But when you're desperate after trying to reach someone for weeks about cross-border tax issues, you'll try anything. The service doesn't provide tax advice - it just gets you connected to the actual IRS representatives who can answer your specific questions about filing requirements when you have income from both countries.
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Carmen Vega
I'm actually embarrassed about this, but I need to correct myself. After my skeptical comment, I decided to try Claimyr out of pure frustration after spending 3 hours on hold with the IRS yesterday. It... actually worked exactly as described. Got a call back in about 45 minutes and spoke to someone at the IRS international tax department who answered all my questions about reporting my Canadian RRSP on my US return. I've been pulling my hair out for weeks trying to figure this out on my own. Sometimes being proven wrong is a good thing!
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Andre Rousseau
One thing nobody's mentioned yet - bank accounts are a HUGE pain with dual citizenship. US FATCA requirements mean you have to report foreign accounts over $10k combined value, and some Canadian banks don't want American clients because of the reporting hassle. I've been dual for 5 years and still discovering new tax headaches every year.
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Zoe Stavros
•Is there any way around the FATCA stuff? Seems ridiculous that I'd have to report my accounts to the US government when I'm living and working fully in Canada.
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Andre Rousseau
•Unfortunately, there's no legitimate way around FATCA reporting requirements as long as you remain a US citizen. It's one of the biggest complaints from Americans living abroad. You must file the FBAR form annually reporting your foreign accounts if their combined value exceeds $10,000 at any point during the year. Some people consider renouncing US citizenship, but that's an extreme step with its own tax implications (potential exit tax) and permanent consequences. Most dual citizens just deal with the extra reporting requirements and find banks that are willing to work with US persons.
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Jamal Harris
Random question from an accountant's wife: has anyone here calculated if it's actually cheaper to pay a Canadian accountant and a US accountant separately, or find one of those specialized cross-border accountants that do both returns?
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GalaxyGlider
•In my experience, a specialized cross-border accountant ends up being cheaper and WAY less stressful. I tried the "two separate accountants" approach first year and ended up playing messenger between them, explaining things back and forth. The specialized accountant knew exactly how to optimize between both systems.
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Gemma Andrews
As someone who's been navigating dual US-Canadian taxation for about 3 years now, I can confirm that while it's complex, it's definitely manageable once you understand the basics. A few key points that might help: 1. You'll almost certainly end up paying less in total taxes than you think. Canadian taxes are generally higher, so the foreign tax credits usually eliminate most US federal tax liability. 2. Don't forget about provincial taxes in Canada - they vary significantly by province and aren't covered under the treaty the same way federal taxes are. 3. If your employer offers stock options or RSUs, get professional advice ASAP. The timing of taxation between the two countries can create some really tricky situations. 4. Consider opening your Canadian accounts before you actually move - some banks are more willing to work with US persons if you establish the relationship while still in the US. The first year is definitely the hardest as you figure everything out, but it gets much more routine after that. Just budget for good professional help at least for the first filing to make sure you're set up correctly!
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Malik Davis
•This is really reassuring to hear from someone who's actually been through it! I'm particularly worried about the stock options situation you mentioned - my US employer does offer RSUs as part of the compensation package. Could you elaborate a bit more on what makes the timing tricky between the two countries? Is it something about when the shares vest versus when they're taxed? I want to make sure I understand this before I make the move so I don't get hit with any surprises later.
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