Different tax logic
In the U.S., mortgage interest on a home can itself be deductible; in Canada it isn't — which is why our Canadian strategies convert debt instead. Structures must be designed per country, never copied across.
A different country is a different discipline — different lenders, different tax logic, different paper. This side of the desk exists for Canadian families whose balance sheets cross the 49th parallel: the Palm Springs and Scottsdale purchases, the U.S. income earner, the family with holdings in both currencies. Kept deliberately separate from our Canadian programs, because mixing the two is how mistakes get made.
In the U.S., mortgage interest on a home can itself be deductible; in Canada it isn't — which is why our Canadian strategies convert debt instead. Structures must be designed per country, never copied across.
Canadian banks mostly won't lend on U.S. property, and U.S. retail lenders struggle with Canadian income and credit files. The gap between the two systems is exactly where files stall — and where a desk earns its keep.
Cross-border files live and die on documentation — income evidenced across two systems, currency, withholding, and title questions the client's accountant and lawyer must bless.
Cross-border capability has been part of this desk from day one: files with U.S. or international income and residency are handled with the documentation and lender access they require, and financing on the Canadian side of a cross-border balance sheet is structured here in-house — including leveraging Canadian holdings to fund U.S. intentions, coordinated with the client's advisors on both sides.
For the Canadian client buying (or refinancing) property in the United States, the desk can now place programs built precisely for the files American banks decline on a technicality:
Underwritten to the property's cash flow (the DSCR method) — no U.S. income documents, no W-2s, no tax returns. Coverage tests flex for tighter files, and interest-only structures can be used to improve them.
No SSN and no U.S. credit history required — Canadian credit does the talking, with strong files reaching higher leverage. Pre-approval letters can be issued in about a day, which wins offers.
One-to-eight-unit rentals, condotels, short-term rentals and vacation homes — typically LLC-held, roughly $200K to $3M on 30-year terms — plus commercial and industrial property through the direct relationship, sized case-by-case against institutional-scale capacity.
Test a specific property in the U.S. rental (DSCR) calculator. The desk packages the file; the U.S. side handles the closing and servicing.
The step before the rental: a short-term loan to buy a U.S. property and renovate it, qualified on the deal rather than on U.S. credit or income. When the work is done, the client sells, or refinances into the 30-year rental program above and holds it, without starting the file over.
Up to 90% of cost and 75% of the after-repair value, whichever gives the lower loan. The purchase and the renovation are financed together, and renovation money is released in draws as the work gets done.
With no U.S. credit report at all: about 70% of the purchase price and 60% of the after-repair value, closed in a U.S. LLC with a U.S. bank account — which is why the LLC question below comes first.
Leverage grows with experience. The top tier, up to 90% of the purchase and up to 100% of the renovation budget, goes to stronger U.S. credit (around 660–680+) and completed flips.
Usually not for U.S. property — most Canadian lenders secure only Canadian real estate. A few banks run U.S. arms with their own limits. The practical routes are a U.S. lender who understands Canadian files, or structuring the borrowing against Canadian assets — choosing between them is precisely the desk's job.
Yes, on investment property. The short-term program finances the purchase and the renovation together, sized to the lower of up to 90% of cost and 75% of the after-repair value, with renovation money released in draws. With no U.S. credit report at all, there is a lane at about 70% of the purchase and 60% of the after-repair value, closed in a U.S. LLC with a U.S. bank account. When the work is done, the client sells, or refinances into the 30-year rental program and holds. It is never for a home the client will live in, and the LLC question below belongs with their cross-border accountant first.
Plainly: our licences are Canadian (British Columbia and Alberta). U.S. mortgages are originated by U.S.-licensed lenders — the desk's role on American files is coordination, structuring, and the introduction to the right lender, alongside your client's cross-border tax and legal advisors. Nothing about that is grey; it's how proper cross-border work is done.
Country by country. The Canadian playbook — Smith Manoeuvre, debt swap, cash damming — exists because Canadian mortgage interest isn't deductible; it doesn't transplant to a U.S. home, where different deductions and structures apply. This page's separation from our Canadian library is deliberate for exactly that reason.
Three things, all belonging to the client's cross-border accountant, all cheaper to fix before title is taken. The holding structure: U.S. lenders routinely close rentals inside an LLC — standard practice for Americans, and a well-known tax trap for Canadians, whose home country treats the LLC differently and can tax the same income twice. Alternatives exist; the structure conversation happens first. The exit: when a Canadian sells U.S. property, U.S. rules withhold a share of the gross sale price at closing — reducible with advance paperwork, painful as a surprise. The estate: U.S.-situs property can expose a Canadian estate to U.S. estate tax, with treaty relief that depends on the size of the worldwide estate. None of this argues against buying — it argues for sequencing the advisors properly, which is the desk's standing practice.
A client with U.S. intentions — a purchase, a refinance, income on both sides — is worth a conversation before they start filling in American web forms.
Arrange a confidential introductionRamin Hallaji, Principal, licensed in British Columbia (BCFSA) and Alberta (RECA) — a private-client desk of Mortgage Guru Financial, Dominion Lending Centres Group · 778-879-6768 · ramin@mortgageguru.ca · Legal & licensing · Privacy policy
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Information only — not an offer of financing, and not tax or legal advice. Private Wealth Financing operates as Mortgage Guru Financial, licensed in British Columbia. Mortgages on U.S. property are originated by U.S.-licensed lenders, with this desk providing coordination and structuring on the Canadian side and introductions on the American side. Cross-border files require the client's own cross-border tax and legal advisors. Further U.S. programs will be published as they are finalized; program parameters shown are indicative capability, with pricing and terms quoted per file.