MangTaxNotes
Moving from Canada to US:
- you file a dual-status return which shows that you are leaving
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- you are an “emigrant” in year of departure
- need to pay departure tax on non-RRSP mutual funds
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- after leaving cannot trade in these funds
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- can hold and sell
- have to report US income after date of departure to CRA, but not liable for Canadian tax on it
Retirement planning:
- 401k and IRA are evil if you will be in Canada when cashing out
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- the 401k/IRA contribution is deductible in US but not in Canada (so effectively you pay tax on the contribution) – NOT SURE ABOUT THIS
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- 100% of distribution (which is growth AND principal) is taxable because it is treated as pension income
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- so you get double-taxed by CRA
- ROTH IRA income is taxable (little advantage after moving back to Canada)
- RRSP withdrawals when in US are taxed at 25% by CCRA, and gains are taxed by IRS, and Canadian tax is deductible
- can still technically contribute to RRSP after leaving, but broker likely won’t take funds, and no tax advantage since no reportable income to CRA
- Canada doesn’t recognize Roth IRAs. Treats them as regular accounts (taxing gains) but may unofficial defer thread
RRSPs and US taxation
- Only RRSP gains are taxable in US thread
- You need to make some kind of election, but looks like the tax on gains can be deferred IRS link
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- Need to go amend return for first year (starting with 2002) with election
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- Each subsequent year you show balance to IRS
- You need to file a form every year, and more forms if you take a distribution thread
- California does not let you defer taxation on gains, but contributions and gains made before arrival to the state are not taxable more
- It’s possible that withdrawing the principle is not taxable… Need to get my brain around this thread
- More info at this page, but it’s out of date
- Most Canadian brokerages won’t let you trade inside your RRSP but TD Waterhouse might
Nelson says: “You should be looking at a tax-managed portfolio (ie. one that does not generate dividends or capital gains yearly) and then cashing these in after leaving US. In such case, you will have no tax to pay on any of the gains, nor Cdn tax on the pre-arrival gains. Or you should be investing in your US home, as you will not be taxed on the gains when you sell up.”
School planning:
- student loan interest is deductible wherever loan is held
- loan probably doesn’t have to be “official” student loan (e.g. loan against line of credit). Keep records.
Health care:
- probably not covered by OHIP as soon as permanently leave country
- Ontario requires 3-month waiting period before you are covered thread. Most provinces give immediate coverage.
General:
- Canadians are always eligible to file 1040 (which may be better than 1040NR because of deductions) due to treaty
Tax preparation (just a list – haven’t tried them):
General linky:
- CCRA International Tax Services Office
- Tie-Breaker Rules
- Grasmick Tax and Financial Forum
- A chump in a very similar situation to mine Combination of TN, F-1 and need to file previous years.
- Cashing out RRSP
Grasmick threads:
- TN and move-year tax filing – Also OHIP and DL comments.
- Deemed Non-Resident and move-year
- Holding non-RRSP mutual funds – You can hold and sell ONLY. Probably have to pay Canadian departure tax on these in move-year.
- Currency exchange for large amounts
- 401k, ROTH IRA, RRSP madness
- Retirement investment vehicles – ROTH IRA is bad if you move back to Canada. Home in US might be good. Also a tax-advantage investment portfolio that does NOT generate cap gains or dividend payments.
- Advice on cashing out RRSP early while in US
- Difference between emigrant and non-resident to CCRA, and contributing to RRSP with no Canadian source income – Emigrant in year of departure, non-resident after that and don’t have to file
- Good explanation of Canadian (double) taxation of 401k and IRA
- Charitable donations
- Scheme for US companies to give matching RRSP contributions
- Anecdote about getting US UI while on TD – Convinced California that she was immediately employable since eligible for TN.
- Canadians can always file 1040 – Can be advantageous over 1040NR.
- Canada vs US health care for early retirement
- Putting money in IRA and withdrawing soon makes no sense – Also 401k matching is usually vested (25%/year for 4 years)
- Student loan interest is deductible regardless of where loan is held – Loans on line of credit should be deductible in US