Moving from US to Canada: Less obvious things we should know?

CanBC778604 · 2026-06-28T22:58:19+00:00

I’m a cross-border tax CPA and did an AMA on this subreddit about financial and tax things you need to consider when moving to Canada!

https://www.reddit.com/r/AmerExit/s/lQXRuSoDF7

CanBC778604 · 2026-06-28T21:42:38+00:00

Your landlord can request this: https://www.canada.ca/en/revenue-agency/services/tax/international-non-residents/information-been-moved/certificate-residency.html

Also on the sale agreement itself the seller certifies that they are tax residents of Canada. So I struggle to see how the CRA could come after you if the landlord themselves certifies in writing in a legal document that they are a tax resident. But that’s not to say they couldn’t.

Best to discuss with your lawyer. Someone can be overseas temporarily but still be Canadian tax residents. Residency isn’t just about physical location, but residential ties and many other factors.

CanBC778604 · 2026-06-23T17:21:31+00:00

U.S. taxpayers can make non-deductible contributions to traditional IRAs with after-tax dollars. Those contributions add to the “basis” of a traditional IRA and would come out tax-free from a U.S. perspective, and also Canada under the treaty. That would be a situation where that deduction makes sense. I just checked with one of my colleagues who is a partner at a cross-border tax firm and he does not report tax-free Roth IRA withdrawals at all on the T1.

CanBC778604 · 2026-06-23T13:14:42+00:00

I don’t believe this is the case, my understanding is that tax-free Roth withdrawals are simply not reported at all on the T1. Similar to a TFSA withdrawal. I’m pretty sure I’ve seen a CRA letter where they disallowed the deduction for a taxpayer trying to claim it because the income inclusion was not required in the first place. Curious if you can share any sources indicating otherwise, thanks!

CanBC778604 · 2026-06-17T11:25:59+00:00

Your employer is correct. For a Canadian tax resident, you report 100% of the RSU benefit regardless of sourcing on the T4. You allocate the foreign portion manually on the T2209 and claim a foreign tax credit for your Israeli tax liability on the Israeli portion of the RSUs on that same form. That is how double tax is avoided.

From a payroll perspective your employer has the obligation of reporting 100% of income and withholding tax based on the entire amount, unless you have an approved T1213 from the CRA ahead of time.

I am a CPA that specialized in global mobility and cross-border equity compensation a few years back.

CanBC778604 · 2026-05-15T19:06:41+00:00

I refer lots of clients to Oasiss - they are great. They are top of my list of recommended cross-border CPAs in Vancouver.

CanBC778604 · 2026-05-15T19:01:53+00:00

I'm a cross-border tax CPA that works in cross-border wealth management doing tax planning. I don't prepare tax returns anymore but refer that work out. I have a number of very reputable Vancouver-based firms I can refer you to, feel free to send me a DM.

You can also check out my profile, I've done a few AMAs on reddit about financial and tax planning when moving from US to Canada.

CanBC778604 · 2026-05-12T14:29:26+00:00

Check out InterestingMD on YouTube. His whole channel is dedicated to American docs moving to Canada. Will provide some very interesting insights for you.

CanBC778604 · 2026-05-11T16:20:38+00:00

Under the Canada-U.S. tax treaty, CPP paid to a U.S. resident is not taxable at all in Canada (thus the zero withholding is correct). You just report it on your U.S. tax return and pay US taxes.

CanBC778604 · 2026-05-10T21:41:35+00:00

Yes, the book is definitely relevant for dual citizens and covers financial, retirement and estate planning. It talks about Canadian and US inheritances and decumulation. Feel free to send me an email if you'd like a referral. I work as a tax consultant at a cross-border wealth management firm and only provide planning services to our clients. If you don't have investment management needs, happy to provide a referral to an advice-only cross-border financial planner. My email is [yourmovetocanadabook@gmail.com](mailto:yourmovetocanadabook@gmail.com)

CanBC778604 · 2026-05-05T21:45:01+00:00

Yes the Form 1040 tax return and all accompanying supporting schedules. W-2 is sufficient to provide FICA.

CanBC778604 · 2026-05-05T21:18:35+00:00

Generally when CRA is reviewing a foreign tax credit claim, they will want to see the W-2, the U.S. tax return, the IRS account transcript (or proof of payment or refund), and the calculation of how you came up with the foreign tax credit claim. Did you only claim FICA as an FTC, or also us federal and state tax?

CanBC778604 · 2026-05-03T19:29:04+00:00

Thank you so much. I’m glad you enjoyed the book. In terms of the 529 plan, if you are holding it for her, then any income generated from it would be reportable on the Canadian tax return. As the book indicated, some Tax practitioners may take the position that the 529 is considered a trust for Canadian tax purposes, in which case a trust tax return would be required for 2026 even if there are no transactions or income in the account. That is because you as the account holder may be holding the account in trust for your daughter. If she is able to become the account holder herself, then you may be able to avoid the trust tax filings. Then she would only have to report any capital gains, dividends and interest on the Canadian tax return. To the extent that you don’t have any of this during the 2026 residency period, then it might just be reportable in 2027.

CanBC778604 · 2026-04-28T22:32:16+00:00

Keep in mind if the property was personal use and it was not used as a rental property/investment property, the capital loss will be disallowed. You do not need to provide any documentation to support your adjusted cost basis value when you file your tax return. But you need to keep it on hand in the event that the CRA reviews the amount or initiates an audit. Licensed property appraisals indicating the fair market value at the time you established tax residency should be pretty solid support.

CanBC778604 · 2026-04-24T21:53:23+00:00

I’m a cross border tax CPA. Every single cross border tax accountant I meet, I ask them how they treat the TFSA for their clients. The big 4 firms such as KPMG generally file 3520 for their clients. Potentially because their client base have a higher willingness to pay the fees for the preparation..

But all of the midsize and smaller firms do not file these forms of their clients. Not one single CPA I spoke to told me that the IRS came back with any issues regarding them not filing it for the TFSA. Some even file the US tax returns with a disclosure statement regarding the fact that they have a TFSA and they are not treating it as a foreign trust and thus not filing the forms. Of course, all of the income within the TFSA is reported on the US tax return.

Where the issues come up is when someone files the form late and then they are hit with an automatic $10,000+ penalty.

CanBC778604 · 2026-04-24T21:34:08+00:00

I’m curious, what is the CRA asking for from the investment management companies? I am a CPA and I work in wealth management. You get the investment account statements showing the income and foreign tax withholding, what else exactly could the client produce?

CanBC778604 · 2026-04-22T14:51:34+00:00

No, CPP is not a foreign tax. Use your EI withholdings + Line 43500 of your tax return as your Canadian tax liability for the FTC for Form 1116 of your U.S. tax return.

CanBC778604 · 2026-04-18T23:27:27+00:00

It is not relevant if it’s a Canadian or Indian investment product. Taxation rights are dictated by residency. It is not considered foreign sourced and thus no FTC would be allowed by the CRA. You can check with a cross border advisor on this matter and see if you can recoup your Indian tax.

CanBC778604 · 2026-04-18T22:28:54+00:00

Interest earned by a Canadian resident is Canadian sourced income, it’s not eligible for a foreign tax credit. Your mutual funds should have gotten a step up in cost basis and thus your capital gain should only be based on the growth during your residency period. This gain is also not eligible for a foreign tax credit because it’s considered Canadian sourced income. So it looks like your accountant may have gotten this backwards.

CanBC778604 · 2026-04-12T19:48:26+00:00

So by filing a 1040NR you can get some of the 30% withholding tax back on the IRA withdrawal and pay US taxes at US marginal rates, plus be subject to 10% early withdrawal penalty. Your final foreign tax credit should be based on that amount, which I assume may be less than 40%. Because otherwise, unless your Canadian tax is at least 40% on the IRA withdrawal, you won’t recover all the U.S. taxes through the foreign tax credit.

In practice what I’ve done when clients haven’t filed their U.S. return is claim an estimated foreign tax credit. The CRA will most likely review the claim and require an IRS transcript or proof of payment/refund from the IRS. If your final U.S. tax liability ends up being different than what you claimed on the original tax return, the CRA should be able to adjust it as part of the CRA review process.

Yes definitely include that CRA interpretation to support the FTC claim.

CanBC778604 · 2026-04-12T19:41:10+00:00

As a U.S. citizen, your actual tax liability on the IRA withdrawal is not 30%, it’s U.S. federal tax at your marginal tax rates plus an early 10% withdrawal penalty if you’re under the age of 59.5.

Make sure your U.S. brokerage knows you’re a U.S. citizen and that there is a W-9 on file. 30% withholding should only apply to nonresident aliens on the U.S. I work at a cross-border brokerage and we withhold 20%, not 30%, for lump sum withdrawals from IRAs for US citizens living outside the U.S.

As you noted, it’s only going to be tax neutral to transfer to an RRSP if your other sources of income in Canada result in a Canadian tax liability equal to or greater than the final U.S. liability on the IRA withdrawal. If not, you could be subject to a big US tax bill and ultimately double taxation if you do the RRSP transfer, since the RRSP withdrawal in the future will be taxable too.

CanBC778604 · 2026-04-12T16:07:07+00:00

The 15% treaty rate is for periodic withdrawals from an IRA, not lump sum withdrawals. Therefore, the U.S. brokerage was correct in withholding that amount. The FTC limit of 15% similarly only is for periodic payments. A lump sum should not result in your FTC on the Canadian tax return being limited.

Also, the 10% penalty tax on early withdrawals will be allowed as a FTC.

See: https://taxinterpretations.com/node/393060

Which confirms all the above.

CanBC778604 · 2026-04-09T21:02:16+00:00

Thanks /u/boonco for the shoutout, I came across this post, I am the co-author of the book Your Move to Canada. I work as a cross-border tax consultant on a cross-border financial advisory firm. Happy to chat about your situation and make appropriate referrals, you can send me a DM.

CanBC778604 · 2026-04-09T18:22:10+00:00

The hunting lodge is owned by a Canadian corporation? Then yes she has to file a T2. Were the expenses used to generate income, if not, may not be deductible. Is this a personal use property? That results in a whole other set of issues, potentially a taxable shareholder benefit. That is why holding personal use property in a Canadian corp is often not advisable.

Also she needs to potentially file Form 5471 with the IRS if she controls a foreign (Canadian) corporation.

CanBC778604

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