Canadians working for US employers, Americans in BC, BC-Washington commuters
Tax for Cross-Border Workers: Canada, BC and Washington
Working across the border usually means returns in both countries, and the right answer depends on where you live, where you do the work and who pays you. We work from our Surrey, BC office, with clients across Greater Vancouver and remotely. Work is led by Gurleen Kaur, CPA licensed in British Columbia and Washington State.
Quick answer
Where do cross-border workers pay tax?
Generally, wages can be taxed where the work is done, and also by the country where you live, with a credit to avoid double tax. Under the treaty, wages for work done in the other country are taxed only at home if they are not more than US$10,000 for the year in that country's currency, or if you are there no more than 183 days in any 12-month period and the pay is not paid by a resident employer or borne by a permanent establishment there (Publication 597). US citizens remain subject to US tax wherever they live.
At a glance
- Treaty wage rule
- US$10,000, or 183 days and no local employer
- Returns
- Often one in each country, with a foreign tax credit
- Social Security
- An agreement generally keeps you in one system
- Washington
- No individual income tax currently; a new high-income tax is set for 2028
- Source
- IRS Publication 597, checked November 1, 2026
Your situation
These are general patterns. Your residency, your days and your employer's set-up decide the answer.
| Situation | What usually applies | Read next |
|---|---|---|
| A Canadian living in BC, working in Washington for a US employer | US wages can be taxed in the US, often on Form 1040-NR. They also go on your Canadian return, with a credit for US tax | Form 1040-NR |
| A Canadian living in BC, working from home for a US company | Work done in Canada is generally taxed in Canada. The employer's payroll set-up needs a look | The treaty in plain English |
| An American living in BC, paid by a US company | Both countries can tax you: a US return as a citizen, and a Canadian return as a resident, with credits | Form 1116 |
| A Canadian who moved to the US for work | Part-year questions in both countries, and residency decides what is taxed | Moving from Canada to the US |
| A short work trip across the border | The treaty wage rule may exempt the pay | Substantial presence calculator |
Payroll and Social Security
- Social Security. Under the US-Canada agreement, employees are normally covered where they work, and it is meant to avoid paying into both systems for the same work. A certificate of coverage can matter for assignments. It does not cover Medicare (SSA).
- Payroll. Whether a US or Canadian employer needs payroll registration depends on where work is done. See cross-border bookkeeping and payroll.
- Wrong withholding. Tax withheld in the wrong country is usually sorted out on returns, so keep your slips.
Washington and BC
Washington does not currently have an individual income tax. Its Department of Revenue describes a new 9.9% income tax from January 1, 2028, for those with adjusted gross income over US$1 million (Washington DOR).
So a commuter often deals with federal US tax and Canadian federal and BC tax. Gurleen Kaur is licensed in British Columbia and Washington State, and our office is in Surrey, BC, serving Greater Vancouver.
When to get help
Get help if:
- You started or stopped working across the border this year
- You work from home in one country for an employer in the other
- You have stock options, RSUs or a retirement plan in the other country
- You were taxed in both countries and credits do not match
- You have missed returns in either country; see behind on US filings
We prepare US returns for cross-border workers and coordinate with your Canadian return. Each engagement starts with a written scope and fixed quote, after we review your records.
How it works
- Send your request. Tell us where you live, where you work and who pays you, using the form below.
- Review and fixed quote. We review your slips and last returns, and give you a written scope and fee.
- Preparation and review. We prepare the returns and go through them with you.
- Filing. The returns are filed, and we keep your file for next year.
What we need from you
- W-2s, T4s and pay stubs
- A record of days worked in each country
- Your employment contract and any equity plan
- US and Canadian returns from last year
- Any letters from the IRS or CRA
Please do not send tax IDs or statements through the website form. If we work together, documents come in through our secure client portal.
Common questions
I live in BC and work in Washington. Which returns do I file?
Usually a US return for the wages, and a Canadian return reporting your worldwide income, with a foreign tax credit for the US tax. Your citizenship and your days matter.
Does Washington tax my wages?
Washington does not currently have an individual income tax. Its Department of Revenue describes a new tax from 2028 for adjusted gross income over US$1 million.
What is the treaty 183-day rule?
Pay for work in the other country is taxed only at home if you are there no more than 183 days in any 12-month period and the pay is not paid by a resident employer or borne by a permanent establishment there, or if it is not more than US$10,000 for the year.
I am a US citizen living in BC. Does the treaty remove my US return?
No. The US taxes its citizens under the saving clause, with limited exceptions. Credits and the treaty's double-tax rules prevent most double tax.
Do I pay Social Security in both countries?
The US-Canada agreement is meant to avoid that for the same work. Employees are normally covered where they work, and it does not cover Medicare.
How much does this cost?
We give a written scope and fixed quote after reviewing your records.
Sources
Every rule and figure on this page links to the IRS, CRA or other official source it comes from. Amounts change; we re-check them before each engagement.
- IRS: Publication 597, Information on the US-Canada Income Tax Treaty
- SSA: Totalization agreement with Canada
- Washington Department of Revenue: Income tax
- IRS: US citizens and residents abroad, filing requirements (reviewed September 28, 2026)
Gurleen Kaur, CPA licensed in British Columbia and Washington State. Last updated November 1, 2026. This page is general information, not tax or legal advice for your situation.
Related guides: US tax accountant in Surrey and Greater Vancouver, The treaty in plain English, Form 1040-NR, Moving from Canada to the US.
Working across the border? Request a quote
Tell us your situation in a few lines. We confirm whether we can help, what records matter and the next step. Substantive advice begins under a paid diagnostic or signed engagement.
Prepared and signed by a licensed US CPA who can represent you before the IRS. Verify Gurleen Kaur's Washington licence (#41150) on CPAverify