International & Cross-Border Tax

Expand globally, stay compliant, and minimize worldwide tax — with one team that does it all.

Mackisen’s cross-border tax lawyers + CPAs handle U.S. personal/corporate tax, non-resident property sales (T2062/ARQ clearance), expatriate tax & payroll equalization, transfer pricing (OECD), permanent establishment questions, treaty positions, FBAR/FATCA, T1135 foreign asset reporting, Reg. 105/102 withholding, W-8/W-9/1042-S, GST/HST/QST for non-residents, and global structuring — so you can scale without tax headaches.

What We Do (End-to-End Cross-Border Compliance & Planning)

1) U.S. Personal & Corporate Tax (1040 / 1040NR / 1120)
Canadian residents with U.S. ties? U.S. owners with Canadian operations? We prepare 1040/1040NR/1120, claim treaty relief, optimize foreign tax credits, and align with T1135/FBAR/FATCA. Dual-status and state filings handled.
Best for: Canadians with U.S. income, expats, U.S. companies in Canada.

2) Non-Resident Real Estate Sales (T2062 / ARQ Clearance)
Selling Canadian property as a non-resident? We obtain CRA T2062/ARQ clearance certificates to release sale proceeds and reduce withholding; file Section 116 returns; coordinate with notaries, lenders, and buyers.
Best for: Non-residents selling condos, homes, apartments, commercial assets.

3) Expatriate Tax, Payroll & Equalization
Inbound/outbound assignments? We design tax equalization policies, run shadow payroll (Reg. 102/CPP/QPP/QPIP), apply totalization agreements (CPP/US SS), and prepare cross-border returns for assignees and executives.
Best for: Employers seconding staff; mobile executives; global mobility programs.

4) Transfer Pricing (OECD / BEPS)
Intercompany goods/services/IP? We create arm’s-length policies, benchmarking, and Master/Local File documentation; defend audits; implement intercompany loan and royalty frameworks.
Best for: Groups with cross-border flows that want audit-proof TP.

5) Global Structuring & Permanent Establishment (PE)
Branch vs subsidiary, LLC/S-Corp pitfalls for Canadians, Canada–U.S. treaty tie-breaker tests, PE risk for remote teams, withholding on dividends/interest/royalties. We design holdings, financing, and cash repatriation that balance operational needs with tax efficiency.
Best for: Companies expanding to the U.S./EU/Asia; investors entering Canada.

6) Cross-Border Sales Tax & Registration (GST/HST/QST & U.S. Nexus)
Non-resident sellers/e-commerce? We assess GST/HST/QST registration, platform and marketplace rules, U.S. sales tax nexus (economic/physical), and build compliant collection/remittance workflows.
Best for: Online retailers, SaaS, marketplaces, B2B services across borders.

Benefits of Partnering with Mackisen

• Double-tax avoided: Treaty positions + foreign tax credits = pay tax once, not twice

• Fewer surprises: Proactive pre-transaction planning (residency, PE, withholding)

• Faster closings: T2062/ARQ clearance done right; coordinated with notary/buyer/lender

• Cleaner audits: TP files, W-8/W-9 packs, FBAR/T1135 done on time and defensibly

• One bilingual team: Montreal-based (EN/FR), serving Quebec, Canada, U.S., and abroad

Why Choose Mackisen (Montreal • Quebec • Canada)

• Tax lawyers + CPAs in one team (treaty, TP, mobility, clearance)

• 35+ years combined cross-border experience; lender/notary/Big-4-grade rigor

• U.S. & Canadian personal/corporate tax, FBAR/FATCA & T1135, Reg. 105/102

• End-to-end delivery: planning → filings → certifications → defense

• Secure portal: encrypted uploads; audit trail; rapid response (24–48h triage)