Cross-Border Tax Chat with
Aragorn Hsing
Analysis of Complex, Real-World Issues with technical precision.
Aragorn K. Hsing
TEP, US Certified Public Accountant (MT)
I’ve spent over a decade working in Canada–U.S. cross-border tax and am currently with Hutcheson & Co., where I focus on complex cross-border matters involving personal taxation, trusts, estates, and U.S. corporations. I’ve had the benefit of working alongside highly regarded practitioners in the field, which has shaped my approach to technical analysis and problem-solving.
Cross-border tax issues are rarely straightforward. More often than not, they involve overlapping tax systems, competing interpretations, and fact patterns that do not fit neatly within standard frameworks. These situations require careful analysis from both sides of the border.
My approach is to break these issues down into structured components and work toward a clear, defensible path forward. This site reflects that process—focusing on the underlying mechanics of cross-border tax rather than simplified summaries.

“Find a job you enjoy doing, and you will never have to work a day in your life.” — Mark Twain
Areas of Expertise & Technical Interest
Cross-Border Trusts & Estates
Analysis of cross-border trust and estate structures, including intergenerational transfers, residency characterization, and exposure to dual tax regimes.
Inbound & Outbound Relocation
Inbound and outbound migration analysis, including impact on exiting and entering into two worldwide tax frameworks.
US-Canada Treaty Analysis
Technical analysis of the Canada–U.S. Income Tax Treaty, including areas where treaty provisions interact imperfectly with domestic law.
Cross-Border Corporate Structuring
Structuring considerations for Canadian corporations entering the U.S. market, with a focus on entity selection, tax exposure, and cross-border efficiency.
U.S. – Canada Tax Analysis
Focused on technically complex cross-border tax matters requiring structured consideration across both U.S. and Canadian tax systems.