Tax planning and analysis is a vital part of any business structure, particularly with cross border aspects. Ingenuity Counsels tax expertise rivals that of any firm, with unparalleled client service and competitive rates. We handle U.S. and cross-border tax planning for individuals, corporations, limited liability companies, partnerships and international operations. We also handle a multitude of U.S. tax and information filings.

Ingenuity Counsel offers sophisticated planning to businesses and individuals with international circumstances. We structure U.S. investments and operations for Canadian individuals and entities, as well as foreign investments and operations for U.S. individuals and entities. Our primary clients are Canadian resident individuals and companies, but we can work with clients throughout the world that require U.S. tax services.

How can we help?

  • Review your U.S. income tax return and answer your questions about how your U.S. income tax return is being prepared.  
  • Advise you on your tax compliance requirements as a U.S. lawful permanent resident (aka LPR or green card holder) or as a commuter green card holder.    
  • Help you find a reliable, experienced cross border income tax professional to prepare your tax returns.   


Americans living in Canada who have violated U.S. tax laws are in danger of prosecution by the United States government. However, they can effectively avoid prosecution and penalties by taking advantage of the IRS Voluntary Disclosure Program or the IRS Streamlined Filing Procedures by self-reporting their tax non-compliance to the IRS before the IRS begins an investigation. While making a Voluntary Disclosure does not guarantee that the IRS will not refer the taxpayer to the Department of Justice for criminal prosecution, it is the IRS’s long-standing policy to not refer for prosecution taxpayers who make a full Voluntary Disclosure of their tax transgressions.  The Voluntary Disclosure Program has received renewed interest lately in the wake of the IRS’s efforts to identify and prosecute taxpayers who used offshore bank accounts to allegedly evade their income tax liabilities.  

Voluntary disclosure is not just for individuals. Corporations, partnerships, trusts, and other entities are eligible to participate in the IRS Voluntary Disclosure Program. Time is of the essence – Once the IRS opens an examination of a taxpayer, that taxpayer is no longer eligible to disclose under the voluntary disclosure program.

The streamlined filing compliance procedures are available to taxpayers certifying that their failure to report foreign financial assets and pay all tax due in respect of those assets did not result from willful conduct on their part. The streamlined procedures are designed to provide to taxpayers in such situations with a streamlined procedure for filing amended or delinquent returns, and terms for resolving their tax and penalty procedure for filing amended or delinquent returns, and terms for resolving their tax and penalty obligations.

The streamlined filing procedures that were first offered on September 1, 2012, have been expanded and modified to accommodate a broader group of U.S. taxpayers. Major changes to the streamlined procedures include:

  • Extension of eligibility to U.S. taxpayers residing in the United States
  • Elimination of the $1,500 tax threshold, and
  • Elimination of the risk assessment process associated with the streamlined filing compliance procedure announced in 2012.

If you have failed to comply with your U.S. tax obligations, including information returns, such as FinCEN Form 114, formerly called the Report of Foreign Bank and Other Financial Accounts or simply the “FBAR”, you need to seek experience U.S. legal counsel immediately to avoid prosecution and penalties.  

The IRS takes these matters seriously and so should you. IRS penalties can be significant! If you have already been contacted by the IRS and assessed a late filing penalty, we can also work with you in dealing with the IRS to waive or reduce the penalty.

Contact us today at 519-252-3888 or by email at to schedule a confidential consultation to discuss your options.