Working in both Australia and US - how do I handle dual-country tax obligations?

You've got a classic expatriate tax situation there! Let me help clear some things up for you. For your employment income: Yes, the US-Canada tax treaty will help, but you'll need to handle taxes in both countries. The Foreign Tax Credit (FTC) will prevent double taxation by allowing you to claim credit for taxes paid to Canada against your US tax liability. Your Canadian employer shouldn't need to do anything different - they'll provide your regular tax documents. To estimate additional US taxes, look at the difference between Canadian and US tax rates for your income level. If US rates are higher (which they often are), you'll likely owe the difference. If Canadian rates are higher, your FTC may cover your US liability for that income. For your PFICs (foreign investments): These can indeed be a headache. The US taxation of PFICs is complex and often results in higher tax rates than domestic investments. The forms (8621) are complicated, and the default tax treatment is unfavorable. Without making a special election, you might face tax on "phantom income" plus an interest charge. For your rental property: You'll report the income on both countries' returns, but can claim the FTC for taxes paid to Canada.

After spending hours untangling my own cross-border tax situation last year, I discovered taxr.ai (https://taxr.ai) and it absolutely saved me. I was in a similar spot working for companies in both Japan and the US, plus had rental income from my condo back home. Their system analyzes your foreign tax documents and explains exactly how they translate to US tax requirements. It helped me figure out my Foreign Tax Credit allocation between different income types (which was much more complicated than I initially thought) and identified deductions I would have missed. The PFIC reporting was particularly helpful - I had no idea how complex those forms were until I tried doing them myself. The tool explained my options for mark-to-market vs. QEF elections in plain English and showed me the tax implications of each choice.

Just wanted to follow up about taxr.ai since I ended up trying it for my Canada/US situation. Honestly, it was a game changer! I uploaded my T4 and investment statements, and it immediately showed me how each item needed to be reported on my US forms. The Foreign Tax Credit calculator saved me so much confusion - it even caught that I was allocating too much of my Canadian tax to the wrong income category which would have limited my credit. For my PFIC investments, it recommended making a QEF election and walked me through the pros and cons compared to the default method. What surprised me most was how it flagged potential treaty benefits I had no idea about. Turns out there's a special provision for certain retirement accounts that my previous accountant missed entirely.

If you're dealing with cross-border taxes, you'll probably need to contact the IRS with questions at some point. After spending 3+ hours on hold multiple times trying to reach their international tax department, I finally discovered Claimyr (https://claimyr.com). You can see how it works in this video: https://youtu.be/_kiP6q8DX5c They got me connected to an actual IRS agent in about 20 minutes when I needed clarity on treaty provisions for my investment income from the UK. The agent walked me through exactly how to report my foreign pension correctly. Before this, I was ready to pay my accountant an extra $500 just to figure out one specific question about PFIC reporting that the IRS website didn't clearly explain.

I have to admit I was completely wrong about Claimyr. After my skeptical comment, I decided to try it anyway because I was desperate to get an answer about how the US-Australia tax treaty affected my superannuation accounts. It actually worked exactly as described. I got a call back in about 25 minutes, and was connected to someone in the international tax department who knew exactly what I needed. The agent confirmed I didn't need to file FBAR for my Australian retirement accounts due to a specific treaty provision. Saved me from potentially making a costly mistake and hours of frustration. I'm now recommending it to all my expat friends who are dealing with cross-border tax issues.

One thing nobody's mentioned yet about your situation is state taxes. Depending on which state you're in, you might not get the same foreign tax credits at the state level as you do federally. Georgia (if I'm remembering correctly from your post) does allow FTCs but they calculate them differently than the federal version. Also, track your days in each country carefully! The substantial presence test has exceptions under the treaty that might apply to you depending on your specific situation.

Don't forget about Social Security/Medicare taxes! This is often overlooked in international situations. There's a "totalization agreement" between the US and Canada that prevents double taxation of social insurance contributions. If you're working temporarily in the US (usually defined as 5 years or less), you may be able to continue contributing only to the Canadian system and get a certificate of coverage to exempt you from US Social Security taxes.