🧾 Taxes

You usually stop being a Canadian tax resident when you cut your residential ties: your home, your spouse or partner and dependants, and your personal property and social ties. You can ask the CRA for an opinion with Form NR73.

When you leave, the CRA treats you as having sold certain property at its fair market value ("departure tax", or a deemed disposition), and you may owe tax on the gain. Canadian real estate, RRSPs, RRIFs and pensions are among the exceptions. If everything you own is worth more than $25,000 when you leave, you also file Form T1161.

File a final Canadian return for the year you leave, enter your departure date, and tell the CRA and your banks you're no longer a resident. As a non-resident you generally stop getting benefits like the Canada child benefit.

You're a U.S. tax resident if you have a green card or meet the substantial presence test: at least 31 days in the current year, and 183 days over three years counting all days this year, one-third of last year's days and one-sixth of the days from the year before.

Snowbirds who meet the test but spend fewer than 183 days in the U.S. in the year, keep a home in Canada and have a closer connection to Canada can file Form 8840 by the tax return due date to stay non-resident.

U.S. citizens and green card holders keep filing U.S. returns on their worldwide income even after moving to Canada. Canada taxes you as a resident from the day you establish residential ties here, on your worldwide income from that date.

The Canada–U.S. tax treaty and foreign tax credits are designed to stop you paying full tax twice on the same income, but you still file in both countries.

A U.S. person (citizen, green card holder or U.S. tax resident) whose foreign accounts add up to more than $10,000 at any time in the year files an FBAR, due April 15 with an automatic extension to October 15. Some people also file Form 8938.

Canadian banks identify accounts held by U.S. persons and report them to the CRA, which passes the information to the IRS. RRSPs, TFSAs and RESPs are exempt from that bank reporting, but that doesn't change your own U.S. filing duties.

• RRSP and RRIF: you can usually keep them when you leave Canada. For U.S. tax, eligible people are automatically treated as deferring tax on the growth until they withdraw (IRS Rev. Proc. 2014-55).
• TFSA: you can keep it, but as a non-resident you build no new room, and contributions made while non-resident are taxed at 1% a month. The CRA warns that TFSA income and withdrawals may be taxed in your new country. U.S. persons should get advice before holding or opening a TFSA.
• RESP: if a subscriber or beneficiary is a U.S. person, ask a cross-border adviser how the U.S. treats it before you contribute.
• 401(k), IRA and Roth IRA: you can usually leave them in the U.S. when you move to Canada. How withdrawals and Roth contributions are taxed in Canada depends on the treaty and elections, so get advice before you contribute or withdraw after moving.