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April 7, 2026 • 21 mins

Of all the conversations Gerry has about cross-border life, the ones involving Canadians who have quietly become US tax residents without realizing it are among the most urgent. 

In this episode, Gerry sits down with Karlene Mulraine of Brij Professional Corporation to walk through what Canadian digital nomads actually need to understand about working in the United States. From the rolling three-year calculation that catches even financially savvy Canadians off guard, to the sticky-state problem that can make double taxation impossible to avoid, to the very real cost of trying to file a cross-border return on your own, this is the conversation to have before your wanderlust makes the decision for you.

  • Why the 183-day rule is not the tax shield most Canadians believe it to be, and how the Substantial Presence Test actually works across three calendar years

  • How Form 8840, the Closer Connection Exception Statement, can protect your Canadian tax status even after you have technically triggered US residency

  • Why Canadian employers are almost never equipped to handle US payroll sourcing, and what that means for the employee working from Palm Springs

  • What happens when you file both a 1040NR and a T1, and why the CRA's foreign tax credit review process is where most DIY cross-border returns fall apart

  • Why New York, California, and Hawaii are sticky states, and why working in any of them may leave you exposed to true double taxation that no treaty can fix

  • How treaty tiebreaker positions under Article 4 of the Canada-US Tax Treaty can be used as a planning tool, not just a last resort

  • What a CRA reassessment looks like in practice when a $30,000 foreign tax credit claim gets reversed, and the interest and penalties that follow

  • Why tracking your days across jurisdictions is the single most foundational habit any cross-border traveler or worker can build


What You'll Learn in This Episode
Resources and Links

Karlene Mulraine - Brij Professional Corporation: https://brij.tax/

Snowbird US Day Tracker App: Available on the App Store and Google Play

Coming Soon: The Snowbirds Expat Radio Book

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