Cross-Border Clients

Reach out today to discuss your unique situation with a cross-border financial advisor at Biscop Cross Border Investment Services.

We help Americans and Canadians who find themselves in the unique situation of having investment accounts on both sides of the border. Whether you are a Canadian resident moving to the US, an American living in Canada, or a US resident who expects to inherit Canadian dollars, we can help.

We are currently one of the only retail investment advisory practices in Atlantic Canada that is licensed and capable of servicing accounts on both sides of the Canada/US border. We are affiliated with both Raymond James Ltd (Canada) and Raymond James USA Ltd (US) and have all of the necessary individual registrations and licensing to deal with all account types and situations that might arise from US residents moving to Canada, or Canadian residents moving to the US (permanently or temporarily). Your accounts will all stay with us, within Raymond James, and will be managed efficiently according to the appropriate Canadian/US financial, tax, and regulatory systems.

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U.S. & Canada Retirement Benefits

Moving Checklist: U.S. to Canada

Moving Checklist: Canada to U.S.

  • Canadians tend to move to the United States to try to escape the cold or to follow an employment opportunity. When they do, they can find themselves in the unfortunate situation of being 'orphaned' by their existing Canadian-based investment advisor, as most Canadian investment advisory firms are not properly registered to do business with Canadians in the United States.

  • An American living in Canada can also end up in the unfortunate situation of being 'orphaned' by their existing U.S.-based advisor, as most U.S. broker dealer and investment advisory firms are not properly registered to do business in Canada.

We are licensed and regulated in both Canada and the U.S., and work closely with clients to translate their personal needs into a strategy for their cross-border accounts. We can also advise clients on cross-border issues such as PFIC rules, IRA and 401(k) rollovers and we maintain professional networks to assist with planning, taxation and legal services.

FAQs

  • 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.
  • 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.
  • 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.
  • 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.
  • 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.
  • 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.
  • 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.
  • 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.
  • 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.


  • 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.
  • Inherited IRAs cannot receive new contributions or rollovers. The account exists solely to distribute assets according to U.S. beneficiary rules.
  • 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.
  • The sale of U.S. real estate by a Canadian who is a non-resident 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.
  • 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.
  • 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.
  • 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.
  • 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.
  • 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.
  • 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.

  • Please refer to Biscop Cross Border’s resources page for more information.


Our Cross-border Solutions

cross border diagram

Part of the Raymond James Financial family of companies, Raymond James (USA) Ltd., or RJLU, is a Canada-based US registered investment firm offering integrated cross-border wealth management solutions to Americans living in Canada and Canadians living in the US. As RJLU advisors, we are licensed and regulated in both Canada and the US, and work closely with clients to translate their personal needs into a strategy for their cross-border accounts. We also advise clients on cross-border issues, such as Passive Foreign Investment Company (PFIC) rules and IRA rollovers, and maintain professional networks to assist with planning, taxation and legal services, as required.

Reach out today to discuss your unique situation with a cross-border financial advisor at Biscop Cross Border Investment Services.

RJLU enables U.S. resident clients to hold both Canadian and U.S. currency accounts. This allows Canadian equities and Canadian dollar denominated fixed income to be added to client portfolios without having to settle in U.S. currency, thus avoiding foreign exchange spreads. U.S. clients can gain expert access to quality Canadian investment grade instruments with our assistance.

Licensed in both the U.S. and Canada, we perform an in-depth financial analysis that offers various cross-border solutions including:

  • Avoiding having to collapse or liquidate your investment accounts of risk significant penalties and tax consequences as a result of your move
  • Assessing limitations on funds transfer and taxations on various holdings
  • Creating a disciplined, unified investment strategy and solid retirement plan for your U.S. and Canadian assets, aimed at giving you financial peace of mind
  • Investing in your portfolio in the currency of your choice via our advanced multi-currency platform


How Does Biscop Cross Border Investment Services Help?

First, Raymond James (USA) Ltd., "RJLU", unlike most investment firms registered with FINRA and the SEC, operates in and across Canada. RLJU is a subsidiary of Raymond James Financial (NYSE:RJF) and has completed an exemption from registration application in Canada to be able to help American citizens living across Canada.

Second, we at Biscop Cross Border Investment Services are registered as advisors in both Canada and the United States. We understand the challenges that the cross-border American citizen faces and have strong connections with other cross-border professionals in areas like tax, trust and estate planning, and insurance and immigration.

By being registered in both countries and well connected to other cross-border centers of influence, we can offer you more than just a Canadian wealth management solution. We can offer you a holistic wealth management solution and coordinate your entire portfolio of assets to keep you on track to achieving your financial goals.

Some of the accounts we manage for clients include:

  • RRSPs and RRIFs for Canadians living in the US.
  • IRAs for Americans living in Canada.
  • Investments for Americans wanting Canadian securities.
  • Investment accounts for US-resident children of Canadian-resident parents.


Reach out today to discuss your unique situation with a financial advisor at Biscop Cross Border Investment Services.


Learn more:

Securities-related products and services are offered through Raymond James Ltd. (RJL), regulated by the Canadian Investment Regulatory Organization (CIRO) and a Member of the Canadian Investor Protection Fund. Statistics and factual data and other information are from sources Raymond James Ltd. (RJL) believes to be reliable but their accuracy cannot be guaranteed. Information is furnished on the basis and understanding that RJL is to be under no liability whatsoever in respect thereof. It is provided as a general source of information and should not be construed as an offer or solicitation for the sale or purchase of any product and should not be considered tax advice. Raymond James advisors are not tax advisors and we recommend that clients seek independent advice from a professional advisor on tax-related matters. Insurance products and services are offered through Raymond James Financial Planning Ltd., which is not a Member – Canadian Investor Protection Fund. Solus Trust Company (“STC”) is an affiliate of Raymond James Ltd. and offers trust services across Canada. STC is not regulated by CIRO and is not a Member of the Canadian Investor Protection Fund.