Ep. 77 Tax Residency Between Canada and the U.S. : What Really Determines Where You’re Taxed

What does it really mean to be a tax resident — and why do so many people accidentally get it wrong when moving between Canada and the United States?

Host Gerry Scott sits down with Nicole Madaisky, a dual-licensed Canadian and U.S. CPA who specializes in complex cross-border lives — from snowbirds and dual citizens to professional athletes and globally mobile families.

With deep experience in international tax and firsthand insight from working with clients on both sides of the border, Nicole breaks down why tax residency is not just a formality — it determines who gets to tax you, how much you owe, and where costly mistakes often happen.

Together, Gerry and Nicole unpack the realities behind some of the most misunderstood rules in cross-border tax planning, including why residency is rarely as simple as counting days or holding a passport.

In this conversation, they explore:

• Why tax residency — not citizenship — often determines which country can tax your worldwide income

• How Canada’s primary and secondary residential ties actually work in practice

• Why the 183-day rule is frequently misunderstood and rarely tells the whole story

• The common ways Americans and Canadians unintentionally trigger tax residency without realizing it

• What snowbirds need to understand about time tracking, treaty rules, and U.S. exposure

• Why buying property in Canada too early can create long-term tax and compliance issues

• How Canadian mutual funds can become a serious problem for U.S. taxpayers

• The foreign reporting requirements that carry steep penalties when overlooked

• Why cross-border planning works best when accountants, advisors, and immigration professionals work as a coordinated team

If you’re living, working, retiring, or even just spending extended time between Canada and the U.S., this episode offers a clear, practical look at the rules that matter most — and the planning steps that can save you from expensive surprises down the road.

Get In touch with Nicole: https://www.nicolemadaiskycpa.com/

Spending time in the U.S.? Take the guesswork out of tracking your days. Download the Snowbirds U.S. Day Tracker app to monitor your stays, stay compliant, and avoid costly surprises at the border.