Should I convert my IRA to a Roth IRA before moving to Canada?

In most cases, yes — and it must be done before you become a Canadian resident. A Roth conversion while you are still a US-only taxpayer triggers US income tax on the converted amount but zero Canadian tax. Once converted, future Roth growth and qualified distributions are excluded from Canadian income under Article XXI of the US-Canada Tax Treaty. After you become a Canadian resident, the same conversion would be taxable in both countries.

What is a sticky state and how does it affect my move to Canada?

Sticky states like California, New York, New Mexico, South Carolina, and Virginia continue to assert taxing authority over former residents even after they leave. California is the most aggressive — it applies a safe harbor test and can tax you for the entire year you depart, plus challenge your departure for years afterward. If you move from California to Canada, you may owe California state tax on worldwide income for the departure year and potentially beyond, depending on your remaining ties.

Can I open a TFSA after moving to Canada as a US citizen?

You can, but you absolutely should not. The IRS treats a TFSA as a foreign grantor trust, requiring annual Forms 3520 and 3520-A. If the TFSA holds Canadian mutual funds (which it almost certainly will), those are PFICs requiring Form 8621 for each fund. The compliance cost alone — typically $1,500 to $3,000 per year in additional preparation fees — far exceeds any Canadian tax benefit. There is zero US tax benefit.

What is the FBAR threshold for Canadian bank accounts?

If the aggregate maximum value of all your foreign (Canadian) financial accounts exceeds USD $10,000 at any point during the calendar year, you must file FinCEN Form 114 (FBAR) electronically by April 15, with an automatic extension to October 15. Foreign accounts include Canadian checking, savings, RRSP, RRIF, TFSA, RESP, and non-registered investment accounts. Willful failure to file carries penalties up to the greater of $100,000 or 50% of the account balance.

How does the US-Canada Totalization Agreement affect my Social Security?

The US-Canada Totalization Agreement lets you combine work credits earned in both countries to qualify for retirement benefits from either system. If you worked 8 years in the US and 5 years in Canada, both periods count toward US Social Security's 10-year (40-credit) qualification threshold. The agreement also prevents double social security taxation — you generally pay into only one country's system at a time based on where you work.

What Canadian tax bracket will I be in after moving?

For 2026, Canadian federal tax brackets are: 15% on the first $57,375; 20.5% on $57,375–$114,750; 26% on $114,750–$158,468; 29% on $158,468–$220,000; and 33% on income over $220,000. Provincial rates stack on top — Ontario adds 5.05% to 13.16%, British Columbia adds 5.06% to 20.5%, and Alberta adds a flat 10%. Combined top marginal rates range from approximately 44% (Alberta/Saskatchewan) to 54.8% (Newfoundland).

Do I need to report my Canadian RRSP to the IRS every year?

Yes. By default, the IRS taxes RRSP income as it accrues. To defer taxation until withdrawal — matching the Canadian treatment — you must attach a written election under Revenue Procedure 2014-55 to your Form 1040 every single year. This replaced the old Form 8891. Missing even one year creates a compliance gap. The RRSP must also be reported on your FBAR (FinCEN 114) and potentially on Form 8938 (FATCA) if asset thresholds are met.

What is Form 8833 and when do I need to file it?

Form 8833 (Treaty-Based Return Position Disclosure) is required whenever you take a position on your US tax return that relies on a US-Canada Tax Treaty provision to reduce or modify your US tax. Common cross-border situations requiring Form 8833 include claiming RRSP deferral, excluding Roth IRA distributions from Canadian income, and claiming the stepped-up basis on property subject to Canadian departure tax. Failure to file carries a $1,000 penalty per undisclosed position under IRC §6712.

What happens to my 401(k) after I move to Canada?

Your 401(k) stays in the US and continues to be governed by US rules. Canada would normally tax the accruing income annually, but Article XVIII(7) of the US-Canada Tax Treaty allows you to elect deferral — the same mechanism as for RRSPs in reverse. Attach a written deferral election to your Canadian T1 return each year. When you eventually take distributions, a 15% US withholding tax applies to periodic payments (reduced from 30% by the Treaty) — file Form W-8BEN with your plan custodian to claim the reduced rate.

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Moving to Canada from the US: The Complete 2026 Tax Checklist (Before, During & After)

May 18, 2026

14 min read

Cross-Border

Moving to Canada from the US: The Complete 2026 Tax Checklist (Before, During & After)

Every year, roughly 10,000 Americans relocate to Canada — for work, family, quality of life, or all three. What most discover too late is that the move triggers a permanent dual-filing obligation that reaches into every corner of their financial life: retirement accounts, bank accounts, investment portfolios, social security, and state taxes. The United States is one of only two countries on earth that taxes based on citizenship, not residence. Moving to Canada makes you a full Canadian taxpayer from the day you arrive, but it does nothing to reduce your US obligations. You will file two national returns — Form 1040 and T1 — every year for the rest of your life as a US citizen.

This checklist is organized as a timeline: what to do 3 to 6 months before you move, what to handle during the transition year, and what becomes a permanent obligation after you land. Every item includes the specific IRS or CRA form involved. If you follow this sequence, you will cross the border with your tax position intact and avoid the five- and six-figure compliance problems that derail Americans who relocate without a plan.

Key Takeaways

US citizens owe US taxes on worldwide income forever — Canadian residency does not suspend or reduce this obligation
Roth IRA conversions done before you become a Canadian resident generate US tax only, with future growth and distributions permanently excluded from Canadian income under Article XXI
Sticky states (California, New York, New Mexico, South Carolina, Virginia) may continue taxing you after you leave — plan your state exit before your international exit
TFSA is a compliance trap for US persons: foreign trust reporting (Forms 3520/3520-A) plus PFIC exposure (Form 8621) with zero US tax benefit
FBAR (FinCEN 114) is required annually the moment your Canadian accounts exceed USD $10,000 in aggregate at any point during the year
Form 8833 is required whenever you rely on US-Canada Tax Treaty provisions to reduce your US tax — and most cross-border filers rely on the Treaty every year

PHASE 1: BEFORE You Move (3–6 Months Prior)

The months before you cross the Canadian border are the only window in which several high-value planning moves are available. Once you establish Canadian residency, most of these opportunities close permanently.

1. Execute a Roth IRA Conversion

This is the single highest-value pre-immigration move for most Americans relocating to Canada. Converting a traditional IRA to a Roth IRA while you are still a US-only taxpayer triggers US income tax on the converted amount — but generates zero Canadian tax because you are not yet a Canadian resident.

Once converted, the payoff is permanent. Under Article XXI(1) of the US-Canada Tax Treaty, qualified Roth IRA distributions are excluded from Canadian income entirely. Future growth compounds tax-free in both countries. For someone with 10, 20, or 30 years of Canadian residency ahead, this one-time US tax cost can save six figures in avoided Canadian tax on retirement distributions.

After you become a Canadian resident, a Roth conversion would be taxable in both countries — destroying most of the benefit. The window closes on your Canadian arrival date.

Form involved: Report the conversion on Form 8606 (Nondeductible IRAs) with your Form 1040 for the conversion year.

2. Sell PFIC Investments

Passive Foreign Investment Companies (PFICs) are the most punitive tax category in the Internal Revenue Code. Any non-US mutual fund, non-US ETF, or non-US pooled investment vehicle is almost certainly a PFIC under IRC §1297. This includes Canadian mutual funds, Canadian-listed ETFs, and offshore investment funds.

Once you are living in Canada, your Canadian bank and advisor will naturally recommend Canadian investment products — all of which are PFICs from the IRS perspective. Each PFIC requires a separate Form 8621 filed annually with your 1040. The tax treatment under the default excess distribution regime is deliberately punitive: gains are allocated across all years of ownership, taxed at the highest marginal rate for each year, and subjected to an interest charge. The alternative — a Qualified Electing Fund (QEF) election or mark-to-market election — requires annual income recognition and detailed fund-level reporting that most Canadian funds cannot provide.

Before you move, liquidate any non-US funds in taxable accounts and replace them with US-listed equivalents (e.g., Vanguard or iShares US-domiciled ETFs). US-listed ETFs are not PFICs, even if they hold international stocks. After arriving in Canada, continue holding only US-listed funds in your non-registered investment accounts.

Form involved: Form 8621 (Information Return by a Shareholder of a Passive Foreign Investment Company or Qualified Electing Fund) — one per PFIC, annually.

3. Plan Your Exit from Sticky States

Before worrying about international tax, deal with your state tax exit. Several US states — nicknamed "sticky states" — continue to assert taxing authority over former residents well after they leave:

California: The most aggressive. Applies a "safe harbor" test and can tax you on worldwide income for the entire year of departure. The Franchise Tax Board routinely audits departing residents for 3 to 4 years after they leave, looking at retained bank accounts, professional licenses, property, and family ties. California does not have a part-year resident credit for moving to a foreign country — you must demonstrate you severed all significant contacts.
New York: Applies a 183-day presence test and a domicile test. Retaining a New York apartment — even one day beyond what you need — can trigger full-year resident status. New York also taxes non-residents on NY-source income, so stock options or deferred compensation from a NY employer continue to be taxed.
New Mexico: Presumes you remain a resident until you establish domicile elsewhere. Moving to Canada counts, but you must affirmatively file a final NM return marking it as "final."
South Carolina: Requires you to file a final return and provide evidence of new domicile to stop residency.
Virginia: Maintains domicile-based taxation and requires affirmative action to abandon Virginia domicile.

If you live in a sticky state, establish your exit 3 to 6 months before your Canada move: close or transfer bank accounts, surrender your driver's license, update voter registration, and — critically — file a part-year or final state return that documents your departure date and new domicile. Keep a paper trail of every tie you sever.

4. Realize Capital Gains Strategically

Long-term capital gains while you are a US-only taxpayer are taxed at 0%, 15%, or 20% depending on income (plus the 3.8% net investment income tax above $200,000 single / $250,000 MFJ). Once you are a Canadian resident, the same gains are taxed in Canada first at your combined marginal rate — up to approximately 54.8% in the highest provinces — with the Foreign Tax Credit mechanism providing offset but adding complexity.

If you have significant unrealized gains in taxable accounts, consider triggering them before your Canadian residency date while the rate is lower and the filing is simpler.

5. Gather All US Tax Documents and Notify the IRS

Before you leave:

File Form 8822 (Change of Address) with the IRS to update your address. This ensures IRS correspondence reaches you in Canada.
If you are changing your name or responsible party for an EIN, also file Form 8822-B.
Gather copies of the last 3 to 5 years of federal and state returns, W-2s, 1099s, and brokerage statements. These are much harder to obtain from Canadian addresses once your US accounts are updated.
Download all historical statements from US brokerage and retirement accounts. You will need cost basis data for years to come.
Maximize your 401(k) and IRA contributions for the partial year — you will lose access to US tax-deferred contribution space once you no longer have US-source earned income.

6. Document Fair Market Values

Under subsection 128.1(1) of Canada's Income Tax Act, new Canadian residents are deemed to have acquired most of their property at fair market value on the day before they arrive. This resets your Canadian cost base — your Canadian capital gains are measured only from your arrival date forward.

Take a screenshot or download a statement from every investment account on your arrival date showing position-level market values. Preserve these records permanently. Missing this documentation creates disputes with the CRA when you eventually sell.

PHASE 2: DURING the Move (Tax Year of Relocation)

The year you move is the most complex tax year of your life. You are a part-year US state resident, a full-year US federal taxpayer, and a part-year Canadian resident — with split-year filing obligations in both countries.

7. Establish Your Canadian Arrival Date

Your Canadian residency start date determines when your Canadian tax obligations begin and how your first-year T1 return is split. Under CRA Folio S5-F1-C1, primary residential ties that establish Canadian residency include:

Taking up a permanent home in Canada (owned or rented long-term)
Bringing your spouse or common-law partner
Bringing your dependent children

In practice, most Americans become Canadian residents on the day they arrive to take up a permanent home. If you fly to Vancouver on August 1 with a signed lease and a job starting August 4, August 1 is almost certainly your Canadian residency start date. Your Canadian T1 covers August 1 through December 31 — worldwide income earned during that period. Income earned January 1 through July 31 is reported only on your US returns.

If your circumstances are ambiguous, file Form NR74 (Determination of Residency Status — Entering Canada) with the CRA to get a formal determination. This protects against a later CRA challenge that shifts your residency date and increases your Canadian tax liability.

8. Handle Split-Year Filing

For the year of your move, you will file:

US Form 1040: Covers the full calendar year (January 1 – December 31), reporting worldwide income as usual. Claim the Foreign Tax Credit on Form 1116 for Canadian taxes paid on income earned after your arrival date.
Canadian T1: Part-year resident return covering your arrival date through December 31. Report worldwide income earned during the Canadian-resident period. Claim Form T2209 (Federal Foreign Tax Credits) for any US tax withheld on US-source income during the same period.
US state return(s): Part-year resident return for your departure state. Sticky states may require a full-year return — see Phase 1 above.

The interaction between these returns is where most errors occur. The Foreign Tax Credit on Form 1116 must be computed on a country-by-country and category-by-category basis, matching Canadian taxes paid against the specific income baskets they relate to. Do not attempt this without cross-border tax software or a cross-border specialist.

9. Canadian Departure Tax on US Property Sales

If you sell your US home or other US-situated capital property during the transition year, the timing relative to your Canadian arrival date matters enormously:

Sold before your Canadian arrival date: Reported only on your US return. No Canadian tax implications.
Sold after your Canadian arrival date: Reported on both returns. Canada taxes the gain on the post-arrival appreciation (using the FMV step-up from subsection 128.1(1) as your Canadian cost base). The US taxes the full gain as usual. The Foreign Tax Credit reconciles the overlap.

The US home sale exclusion under IRC §121 ($250,000 single / $500,000 married) applies regardless of where you live when you sell, as long as you owned and used the home as your principal residence for at least 2 of the 5 years before the sale. Time your sale to preserve this exclusion.

10. Open Canadian Bank Accounts — and Trigger FBAR

The day you open a Canadian checking account, you create an FBAR obligation. If the aggregate maximum balance across all your Canadian financial accounts exceeds USD $10,000 at any point during the calendar year, you must file FinCEN Form 114 (FBAR) electronically through the BSA E-Filing System.

"All foreign financial accounts" includes: checking, savings, RRSP, RRIF, RESP, TFSA, non-registered investment accounts, and in some cases employer pension accounts. The threshold is aggregate — if you have five accounts with $2,500 each, you are over the $10,000 threshold.

Start tracking the monthly high-water-mark balance for every Canadian account from day one. You will need the annual maximum balance for FBAR reporting, and reconstructing this from statements years later is painful.

FBAR deadline: April 15, with automatic extension to October 15. Penalties for willful failure: up to the greater of $100,000 or 50% of the highest account balance, per account, per year.

11. Get Your Social Insurance Number (SIN)

Apply for a SIN at a Service Canada office immediately after arriving. You need it to work legally, open registered accounts (RRSP, TFSA — though you should not open a TFSA), and file your Canadian T1 return. Processing is typically same-day if you apply in person with your work permit or permanent resident card.

PHASE 3: AFTER You've Moved (Ongoing Obligations)

These obligations apply every year for as long as you are a US citizen living in Canada. They do not expire, reduce, or become optional over time.

12. Dual Filing — Every Year, Both Countries

Your annual filing calendar looks like this:

February 28 (Canada): T4 slips and other information slips issued by Canadian employers/payers
March 15 (US): Form 3520-A due if you have a TFSA or other foreign trust (you should not have a TFSA — but if you do, this is the earliest hard deadline)
April 15 (US): Form 1040 due (automatic 2-month extension to June 15 for taxpayers abroad, but interest accrues from April 15 on any balance owed). FBAR (FinCEN 114) also due April 15 with automatic extension to October 15.
April 30 (Canada): T1 return due (June 15 if self-employed, but any balance owed accrues interest from April 30)
June 15 (US): Extended due date for Form 1040 for US persons living abroad
October 15 (US): Final extended due date for Form 1040 (if Form 4868 filed) and FBAR

13. Foreign Tax Credit — Your Primary Double-Tax Shield

The Foreign Tax Credit (Form 1116) is the mechanism that prevents double taxation. For most income levels, Canadian combined federal-provincial rates exceed US rates — meaning the FTC eliminates your US tax on Canadian-source income entirely, often generating excess credits.

Do not claim the Foreign Earned Income Exclusion (FEIE, Form 2555) on the same income. The FEIE caps at approximately $130,000 (2026, indexed) and applies only to earned income. Because Canadian rates are high and the FTC is dollar-for-dollar, the FEIE almost always produces a worse outcome for Americans in Canada. Run both calculations before filing, but expect the FTC to win.

14. RRSP: Your Best Cross-Border Retirement Vehicle

Contributing to a Canadian RRSP makes excellent sense for US persons with Canadian earned income. Contributions are deductible from Canadian income, and Article XVIII(7) of the US-Canada Tax Treaty allows you to elect deferral of US taxation on RRSP income until actual withdrawal — matching the Canadian treatment.

This deferral is not automatic. Each year you must attach a written election under Revenue Procedure 2014-55 to your Form 1040, identifying each RRSP account by number and certifying the election. This replaced the old Form 8891. Missing even one year creates a compliance gap that is expensive to fix retroactively.

The RRSP must also be reported annually on your FBAR (FinCEN 114) and, if applicable, on Form 8938 (FATCA Statement of Specified Foreign Financial Assets) — required if foreign assets exceed $200,000 at year-end or $300,000 at any point ($400,000/$600,000 for married filing jointly).

15. RRSP vs. 401(k) — Key Differences

If you still have a 401(k) from your US employment, it stays in the US and continues under US rules. Canada would normally tax the accruing income annually, but the same Treaty Article XVIII(7) deferral election applies — attach a written statement to your Canadian T1 each year.

Key comparison for ongoing planning:

RRSP contribution limit (2026): 18% of prior-year earned income, up to $32,490 (indexed)
401(k) contribution limit (2026): $23,500 employee deferral ($31,000 if age 50+). You generally cannot contribute to a US 401(k) without a US employer.
Employer RRSP matching: Common in Canada through Group RRSPs or Defined Contribution Pension Plans
Withdrawal tax: Both are taxed as ordinary income on withdrawal. File Form W-8BEN with your US plan custodian to claim the Treaty-reduced 15% withholding rate on periodic 401(k) distributions (down from the default 30%).

16. TFSA Warning — Do Not Open One

Canada's Tax-Free Savings Account is one of the best savings vehicles ever created — for Canadians without US tax obligations. For US persons, it is a compliance disaster with zero offsetting benefit.

The IRS treats a TFSA as a foreign grantor trust, requiring:

Form 3520 (Annual Return to Report Transactions with Foreign Trusts) — due with your 1040
Form 3520-A (Annual Information Return of Foreign Trust with a US Owner) — due March 15
Form 8621 for each Canadian mutual fund or ETF held inside the TFSA (PFIC reporting)

Penalty for failure to file Form 3520-A: 5% of the trust's asset value per year. On a $75,000 TFSA, that is $3,750 annually in penalties alone — before any additional tax or preparation fees. The compliance cost typically runs $1,500 to $3,000 per year in additional accountant fees.

Many Canadian banks automatically include a TFSA in new account packages. Instruct your banker explicitly to omit it.

17. CPP/QPP Contributions and US Reporting

As a Canadian employee, you will pay into the Canada Pension Plan (CPP) — or the Quebec Pension Plan (QPP) if you work in Quebec. For 2026, the CPP employee contribution rate is 5.95% on pensionable earnings between $3,500 and approximately $73,200 (first ceiling), plus an additional 4% on earnings between the first and second ceilings (approximately $73,200 to $81,200). Employer contributions match.

For US tax purposes, CPP/QPP contributions are treated as foreign social security taxes. They are not deductible on your US return, but the US-Canada Totalization Agreement (effective August 1, 1984) prevents double social security taxation. Under this agreement:

If you work for a Canadian employer in Canada, you pay into CPP/QPP only — not US Social Security
If you are posted to Canada temporarily by a US employer (up to 5 years), you may remain covered under US Social Security only — your employer files a Certificate of Coverage
Work credits earned in both countries can be combined to qualify for benefits from either system. If you worked 8 years in the US and 5 years in Canada, both periods count toward US Social Security's 10-year (40-credit) qualification threshold.

When you eventually receive CPP benefits, they are taxable on both your Canadian T1 and US Form 1040 — with the Foreign Tax Credit preventing double taxation.

18. FBAR + FATCA — Every Year, No Exceptions

These two reporting requirements apply annually for as long as you hold Canadian financial accounts:

FBAR (FinCEN Form 114): Required if aggregate maximum balances across all foreign accounts exceed USD $10,000 at any point during the year. Filed electronically through the BSA E-Filing System. Due April 15, automatic extension to October 15. This is a separate filing from your tax return — it goes to FinCEN, not the IRS.

FATCA (Form 8938): Required if specified foreign financial assets exceed the applicable threshold ($200,000 year-end / $300,000 any-point for single filers abroad; $400,000 / $600,000 for married filing jointly abroad). Filed as an attachment to your Form 1040. Overlaps significantly with FBAR but serves a different legal purpose and goes to the IRS, not FinCEN. You must file both if both thresholds are met.

Canadian banks report your account information directly to the IRS under the Canada-US FATCA Intergovernmental Agreement (IGA) — but your independent filing obligation exists regardless of what your bank reports.

19. Form 8833 — Treaty Position Disclosure

Every time you take a position on your US return that relies on the US-Canada Tax Treaty to reduce or modify your US tax, you must disclose it on Form 8833 (Treaty-Based Return Position Disclosure). For most cross-border filers, this is required every year. Common treaty positions that trigger Form 8833:

RRSP deferral under Article XVIII(7)
Excluding Roth IRA distributions from Canadian income under Article XXI
Claiming the stepped-up basis on property subject to Canadian arrival FMV reset
Reduced withholding rates on cross-border pension distributions

Penalty for undisclosed treaty positions: $1,000 per failure under IRC §6712. Attach Form 8833 to your 1040 every year you claim any treaty benefit.

2026 Canadian Federal Tax Brackets

For planning purposes, here are the 2026 Canadian federal income tax brackets (indexed for inflation):

Taxable Income (CAD)	Federal Rate
$0 – $57,375	15%
$57,375 – $114,750	20.5%
$114,750 – $158,468	26%
$158,468 – $220,000	29%
Over $220,000	33%

Provincial rates stack on top. Combined top marginal rates for the most common destination provinces:

Ontario: 53.53% (provincial top rate 13.16%)
British Columbia: 53.50% (provincial top rate 20.5%, but lower brackets offset)
Alberta: 48.00% (provincial flat rate 10% — lowest in Canada)
Quebec: 53.31% (provincial top rate 25.75%, but includes the Quebec abatement)
Manitoba: 50.40% (provincial top rate 17.4%)
Saskatchewan: 47.50% (provincial top rate 14.5%)

For Americans accustomed to combined federal-state rates in the 30% to 45% range, Canadian rates are materially higher — but the Foreign Tax Credit ensures you are not paying both. You pay the higher of the two countries' rates, not the sum.

Complete Forms Reference

Every form an American in Canada may need to file, organized by country:

United States (IRS / FinCEN):

Form 1040 — US Individual Income Tax Return (annual, full-year worldwide income)
Form 1116 — Foreign Tax Credit (Canadian taxes paid offset US tax)
Form 8833 — Treaty-Based Return Position Disclosure (treaty elections)
Form 8938 — FATCA Statement of Specified Foreign Financial Assets
FinCEN Form 114 — FBAR (Report of Foreign Bank and Financial Accounts)
Form 3520 — Foreign Trust reporting (TFSA, if applicable)
Form 3520-A — Foreign Trust annual information return (TFSA, if applicable)
Form 8621 — PFIC reporting (Canadian mutual funds/ETFs)
Form W-8BEN — Certificate of Foreign Status (for Treaty withholding rates on US retirement distributions)
Form 8822 — Change of Address
Form 8606 — Nondeductible IRAs / Roth Conversions
Form 2555 — Foreign Earned Income Exclusion (rarely optimal for Canada)
Revenue Procedure 2014-55 statement — Annual RRSP deferral election (attached to 1040)

Canada (CRA):

T1 — Canadian Individual Income Tax Return (part-year in arrival year, full-year thereafter)
T2209 — Federal Foreign Tax Credits (US tax paid offsets Canadian tax)
Form NR74 — Determination of Residency Status (Entering Canada)
Revenue Procedure 2014-55 statement — Annual 401(k)/IRA deferral election (attached to T1)

Frequently Asked Questions

Do I still have to file US taxes after moving to Canada?

Yes — permanently. The United States taxes citizens and green card holders on worldwide income regardless of where they live. You will file both a US Form 1040 and a Canadian T1 return every year. The Foreign Tax Credit generally prevents double taxation, but the filing obligation never ends unless you renounce US citizenship.

Should I convert my IRA to a Roth before moving to Canada?

In most cases, yes — and it must be done before you become a Canadian resident. A Roth conversion while you are a US-only taxpayer triggers US tax but zero Canadian tax. Future Roth growth and qualified distributions are then permanently excluded from Canadian income under Article XXI of the Treaty.

What is a sticky state?

States like California, New York, New Mexico, South Carolina, and Virginia that continue asserting taxing authority over former residents after they leave. California is the most aggressive — its Franchise Tax Board can tax worldwide income for the entire departure year and audit you for 3 to 4 years afterward.

Can I open a TFSA in Canada as an American?

You can, but you should not. The IRS treats it as a foreign trust (Forms 3520/3520-A annually) with likely PFIC exposure (Form 8621 per fund). Compliance cost alone typically runs $1,500 to $3,000 per year with zero US tax benefit.

When is my FBAR due?

April 15, with an automatic extension to October 15. The FBAR (FinCEN Form 114) is required if your Canadian financial accounts exceed USD $10,000 in aggregate at any point during the year. It is filed electronically through the BSA E-Filing System — separately from your tax return.

How does the Totalization Agreement help me?

The US-Canada Totalization Agreement lets you combine work credits from both countries to qualify for Social Security or CPP benefits. It also prevents double social security taxation — you pay into only one system at a time based on where you work.

What is the top tax rate in Canada?

The top federal rate is 33% on income over $220,000 (2026). Combined with provincial rates, the top marginal rate ranges from approximately 44% in Alberta to 54.8% in Newfoundland. Ontario's combined top rate is 53.53%.

Do I need to report my RRSP to the IRS?

Yes — every year. You must attach a written election under Revenue Procedure 2014-55 to your Form 1040 to defer US taxation on RRSP income. The RRSP must also appear on your FBAR and potentially Form 8938 (FATCA).

What is Form 8833?

Form 8833 discloses treaty-based positions on your US return. It is required whenever you rely on the US-Canada Tax Treaty to reduce your US tax — which most cross-border filers do every year for RRSP deferral, Roth exclusion, or reduced withholding rates.

What happens to my 401(k) after moving to Canada?

It stays in the US under US rules. Canada would normally tax the accruing income annually, but Article XVIII(7) of the Treaty allows deferral via an annual election attached to your Canadian T1. When you take distributions, file Form W-8BEN with your plan custodian for the Treaty-reduced 15% withholding rate.

Moving to Canada from the US? Get Your Tax Plan Before You Cross the Border.

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