Webinar Replay: 2025 Cross-Border Conference: Strategies for U.S. Expansion

Tax Considerations for South-Bound Business Expansion

Jonah Spiegelman | Principal Cross-Border Tax and Estate Planning Lawyer, Polaris Tax

Moving a Canadian business into the U.S. opens powerful opportunities—but it also changes your entire tax landscape. Jonah Spiegelman breaks down the key structures, filings, and timing decisions that help founders expand south with clarity and confidence.

Key Insights:

  • Choose your U.S. entry model carefully. Whether you sell directly, form a branch, or create a subsidiary, each path comes with unique tax rules.
  • Understand presence. Physical or economic presence can trigger U.S. tax obligations—plan before you operate.
  • Coordinate residency shifts. Exiting Canada without planning can create unexpected departure taxes.
  • Avoid double taxation. Align entity types and tax treaties so income isn’t taxed twice.
  • Get filings right. Missing forms like 5471 or 1120F can mean major penalties.

Smart structuring keeps expansion exciting, not expensive.