Cross‑Border Wealth Management: Canada ↔ U.S.

Why Choose Us?

• Deep Expertise in Canada-U.S. Cross-Border Investment Strategy
• Integrated Financial Planning Across Borders
• Collaborative Approach with Legal & Tax Advisors
• Tailored Solutions for Individuals and Businesses

To learn more, you can reach out to us by submitting a request on our contact page here:

https://www.raymondjames.ca/crossborderinvestmentadvisors/contact-us

Common Questions

Can you manage my annuity?

• Annuities are insurance products, not investment or brokerage products. Accordingly, we are not permitted to deal with annuities in any capacity, nor are we permitted to provide any advice on the matter. We recommend seeking advice from a qualified cross‑border accountant or attorney.

Should I sell My IRA Holdings Before I Move?

• It’s best to seek advice before taking any action since selling your IRA holdings may trigger capital gains taxes, while withdrawals from a traditional IRA are taxed as ordinary income. If you plan to move to Canada and maintain the IRA, you may want to consider how distributions will be taxed in both countries. Biscop Cross Border can help with this.

How are U.S. IRA withdrawals taxed in Canada?

• Canada generally treats withdrawals from a U.S. IRA as pension income, which means they are taxable when paid. U.S. withholding tax may apply, but Canadian residents can often claim a foreign tax credit to reduce double taxation under the Canada‑U.S. tax treaty.

What happens when a Canadian inherits a U.S. IRA?

• The inherited IRA remains subject to U.S. retirement account rules, including required minimum distribution schedules. Withdrawals are taxable in both countries, but treaty relief may help offset U.S. tax paid when the income is reported in Canada.

Do Canadians pay U.S. estate tax on inherited U.S. investments?

• U.S. estate tax generally applies only if the deceased’s total worldwide estate exceeds the U.S. exemption amount. Most Canadians do not trigger U.S. estate tax, but the estate may still need to file a U.S. estate tax return depending on asset size and structure.

Can I keep my Roth IRA after moving to Canada?

• Yes, an existing Roth IRA can usually be maintained after becoming a Canadian resident. To preserve its tax‑favored status in Canada, a one‑time treaty election is required, and future contributions should not be made once Canadian residency begins. If Roth IRA contributions are made once the one-time treaty election is in place, the election is no longer valid, and Canada can tax the growth and withdrawals from the plan.

Are TFSAs taxable for Americans living in Canada?

• While TFSAs are tax‑free in Canada, the IRS does not recognize them as tax‑free accounts. Income earned in a TFSA is generally taxable to U.S. citizensand may trigger additional U.S. reporting requirements. Biscop Cross Border can help develop a plan of action to minimize tax implications.

What are PFICs and why are they bad for U.S. citizens in Canada?

• PFICs (Passive Foreign Investment Companies) are non‑S. corporations that primarily earn passive income or hold passive assets. An investor holding PFIC investments faces punitive U.S. tax and reporting rules.   Common examples include Canadian mutual funds and ETFs, making them problematic for U.S. taxpayers living in Canada.

Can I hold U.S. mutual funds while living in Canada?

Generally, no. While U.S. mutual funds are not PFICs for U.S. tax purposes, regulatory restrictions often prevent Canadian residents from holding or purchasing them through Canadian accounts. In addition, holding certain U.S.-registered funds while residing in Canada may create tax compliance and reporting challenges.

Biscop Cross Border has various blog articles that we have created to answer common questions here: https://www.raymondjames.ca/crossborderinvestmentadvisors/blog

How do foreign tax credits work between Canada and the U.S.?

• Foreign tax credits are designed to reduce double taxation by allowing tax paid in one country to offset tax owed in the other. Credits are subject to limits and matching rules, which makes proper income classification important.

Can you add money or roll accounts into an inherited IRA?

• Inherited IRAs cannot receive new contributions or rollovers. The account exists solely to distribute assets according to U.S. beneficiary rules.

Is there an early withdrawal penalty on an inherited IRA?

• Inherited IRAs are not subject to the 10% early‑withdrawal penalty, unless a spousal beneficiary elects to treat the inherited IRA as their own account and makes a withdrawal from the new, rolled over IRA before age 59 ½. However, failing to take required distributions on time can result in significant IRS penalties.

How is U.S. real estate taxed when a Canadian sells it?

• The sale of U.S. real estate by a Canadian who is a nonresident alien of the U.S. is subject to the U.S. FIRPTA withholding rules and comparable rules in certain states. A U.S. Form 1040NR return and where applicable, a state return, must be filed to report the capital gain.  The capital gain must also be reported on the Canadian tax return with foreign tax credits allowed based on the amount of tax calculated on the U.S. tax returns.

What is Canada’s deemed disposition rule at death?

• Canada does not levy an estate tax, but at death it assumes most assets were sold at fair market value. Any resulting capital gains are taxable before assets pass to beneficiaries.

Do Americans in Canada need to file FBAR and Form 8938?

• Many Americans living in Canada must report certain foreign financial accounts using FBAR and/or Form 8938. Filing requirements depend on account balances and ownership.

How are RRSP withdrawals taxed by the United States?

• RRSP withdrawals are generally taxable on a U.S. Form 1040 return when received. Treaty provisions allow U.S. taxpayers to defer U.S. tax on RRSP growth, but distributions are usually taxed as ordinary income. Foreign tax credits are allowed for Canadian taxes on the RRSP withdrawals.

Do my Social Security Credits transfer to Canada? Can I get Social Security and CPP at the same time? What about OAS?       

• No, your U.S. Social Security credits don’t transfer to Canada, but the U.S.-Canada Totalization Agreement allows you to combine work credits from both countries to qualify for benefits. You can receive Social Security, CPP and OAS at the same time, as they are separate programs, though benefits may be prorated based on your combined work history.

Are gifts between Canadians and Americans taxed?

• Canada does not impose a gift tax, but gifting appreciated property may trigger capital gains tax. The U.S. has gift tax rules that may require filing, depending on the giver’s status and the amount transferred.

How is U.S. source investment income taxed in Canada?

• S. source investment income, including interest, dividends and capital gains are taxable for residents of Canada. U.S. non-resident withholding taxes may apply to dividends, but foreign tax credits can often be used to reduce overall tax exposure.

What else should I know before I move to Canada?

Please refer to Biscop Cross Border’s resources page for more information. https://www.raymondjames.ca/crossborderinvestmentadvisors/resources

Summary

Cross-border wealth management between Canada and the U.S. is complex—but with the right strategy, it can unlock significant opportunities for growth and protection. From minimizing double taxation and optimizing retirement accounts to safeguarding your estate and managing investments across jurisdictions, expert planning ensures your wealth works seamlessly on both sides of the border.

Don’t leave your financial future to chance. Biscop Cross Border understands the Canada-U.S. tax treaty, compliance requirements, and cross-border investment strategies.