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Sophie Duck

Working in both Australia and US - How to handle dual-country taxation?

I'm in a bit of a pickle with my taxes and hoping someone can point me in the right direction! I'm a Canadian citizen temporarily living in Georgia for my husband's job assignment (since May 2024). I've got this weird employment situation where I'm working part-time remotely for my Canadian employer while also picking up part-time work with a US company here. According to what I've researched, I qualify as a US tax resident under the substantial presence test. To complicate things further, we have some investments back home (need to file those PFIC forms I guess?) and we co-own a rental property in Canada that's generating income while we're away. From what I understand: - The tax treaty should let me claim Foreign Tax Credit for my Canadian income, but I'm confused about how this affects my Canadian tax return beyond just listing the US income. Does my Canadian employer need to do anything special for my 2025 tax documents? And is there any way to estimate if I'll owe additional taxes when filing my US return? - For the PFIC filing, we may need to pay tax on dividends - anyone know how to estimate how much this might be? We were told if we planned to stay longer, we should probably sell our holdings, which makes me think the tax hit must be significant (though my investments are only about $40k with maybe $3-4k in dividends). I do have an accountant, but this situation is so confusing that I want to understand it myself too! We're married and planning to file jointly. Happy to provide any other details that might help!

This is definitely complex but not unusual! I've worked with several clients in similar situations. Here's what you need to know: For your employment income, the US-Canada tax treaty indeed allows for Foreign Tax Credits, but you'll likely still face some tax liability in both countries. Your Canadian employer doesn't need to do anything special for your documents - they'll issue normal tax forms. However, you should inform them of your US residency status as it might affect their withholding obligations. To estimate additional US tax, compare the tax rates between Georgia and Canada for your income brackets. If Canadian rates are higher, you'll likely have sufficient credits to offset US tax. If US rates are higher, you'll owe the difference. For your PFICs (foreign investments), the taxation can be punitive under US rules. The reason you were advised to sell for longer stays is that PFIC taxation often results in the highest possible ordinary income rates plus an interest charge on deferred tax. There's no simple calculation as it depends on holding period and performance history. For your rental property, you'll report the income on both returns, but can claim FTCs for taxes paid. Don't forget to properly depreciate the property on your US return, which might differ from Canadian treatment.

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Thank you so much for this helpful explanation! I didn't realize the PFIC taxation could be that punitive - no wonder we were advised to sell. Do you know if we need to make any estimated tax payments in the US to avoid penalties, or can we just settle up when we file? Also, for the rental property, are there specific forms I need to file beyond Schedule E? I'm trying to gather all the documentation I'll need.

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If you expect to owe more than $1,000 in tax when you file, you should make estimated tax payments to avoid underpayment penalties. Form 1040-ES is used for this purpose, and payments can be made online through IRS Direct Pay or EFTPS. For the rental property, Schedule E is the primary form, but you'll also need to file Form 8833 to claim treaty benefits related to the property. Additionally, ensure you're tracking all eligible expenses including mortgage interest, property taxes, insurance, maintenance, and depreciation. Keep detailed records of the property's original value, improvements, and the exchange rate used for converting Canadian dollars to USD for your US return.

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After reading your post, I had to share my experience with a similar situation last year. I was working between the UK and US, and the tax paperwork was giving me serious headaches until I found taxr.ai (https://taxr.ai). It really helped me understand my situation better. The platform analyzed all my documents from both countries and explained exactly how the tax treaty applied to my specific situation. What I found particularly helpful was their explanation of Foreign Tax Credits and how they calculated potential tax liabilities in both countries. For your PFIC concerns, they have specialized guidance on that too. I had some foreign mutual funds that qualified as PFICs, and they helped me understand the exact tax implications and reporting requirements.

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Did you find that taxr.ai was able to handle all the complex forms? I'm in a similar situation (working in Japan and US) and I'm drowning in paperwork from both countries.

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How does this compare to using an accountant? I'm in a US/Germany situation and my accountant charges me a fortune because of the complexity, but I'm worried about missing something if I try to handle it myself.

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One thing I didn't see mentioned yet is state taxation. Remember that while the US has tax treaties at the federal level, many states don't recognize these treaties! When I was working between Canada and Minnesota, I ended up with unexpected state tax liability despite having foreign tax credits at the federal level. Check if Georgia has any special provisions for international workers or if they fully tax worldwide income. Some states are more aggressive than others in taxing international income.

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That's a great point I completely overlooked! Do you know if Georgia specifically has any special rules for this? Or where I should look to find out? I've been so focused on the federal side I haven't even thought about state implications.

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Georgia does tax residents on worldwide income, unfortunately. You'll need to file Georgia Form 500 and report all income, including what you earned in Canada. Georgia doesn't automatically respect federal treaty positions, but they do allow a credit for taxes paid to foreign countries to avoid double taxation. Look for the "Credit for Taxes Paid to Another State or Country" section on your Georgia return. The credit is limited to the amount of Georgia tax attributable to the foreign income. The Georgia Department of Revenue website has detailed instructions, or you can call them directly at 1-877-423-6711 for clarification on your specific situation.

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Quick tip about PFICs - if your total foreign assets are under $50k for a single filer or $100k for joint filers, you might not need to file Form 8938 (FATCA reporting). But you likely still need to file FinCEN Form 114 (FBAR) if your foreign accounts exceeded $10k at any point during the year. For the PFIC specifically, consider making a QEF election if possible (depends on if the fund will provide you with an annual information statement). It's generally better tax treatment than the default PFIC rules.

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Adding to this great advice - if you didn't make the QEF election in the first year you held the PFIC, you might be able to make a late election using a "purging" procedure, but it's complicated and might result in immediate taxation of accumulated earnings. Sometimes it's still worth it to avoid the punitive default PFIC tax regime going forward. Also, keep an eye on the exchange rate fluctuations! The IRS allows several methods for currency conversion, and choosing the right one can make a significant difference in your tax liability.

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