A cross-border financial plan has to work under two tax systems at once. Canada taxes by residence; the US taxes its citizens wherever they live. Retirement accounts, investments and estates are treated differently on each side, and the US-Canada tax treaty decides most of the overlaps. A good cross-border advisor plans with the treaty from the first meeting rather than fixing problems after you’ve moved.
A rare specialty
Few firms name cross-border planning at all. In our study of fee-only firm websites, it was one of the rarest specialties firms backed with a quote on their own site.
Two regulators, one plan
US advisers register with the SEC or their state. Canadian advisers register with a provincial securities regulator. An advisor generally needs to be registered where the client lives, so a household that moves, or lives in one country with accounts in the other, may need both. Some firms are registered on both sides. Others work in pairs, with a firm on each side coordinating. Either can work; what matters is that you know who is responsible for which accounts before you start.
The treaty is the design constraint
The tax treaty settles which country taxes what, and it touches nearly every part of a plan.
| Situation | What to know |
|---|---|
| RRSP or RRIF, now living in the US | The account can stay in Canada. US tax on its growth is deferred automatically since Revenue Procedure 2014-55; withdrawals are taxed under treaty rules. |
| Roth IRA, now living in Canada | Growth can stay tax-free in Canada only with a one-time treaty election, and new contributions after you move can undo it. |
| TFSA, as a US citizen | The US doesn’t recognize it: its income is taxable in the US and it can bring extra reporting. |
| Canadian mutual funds, as a US person | Often treated as passive foreign investment companies in the US, with punishing tax and reporting. |
| Leaving Canada | Most property is treated as sold on the day you leave (departure tax), with exceptions such as Canadian real estate and registered plans. |
| Death | Canada taxes a deemed sale at death; the US has an estate tax, which can reach Canadians with US property. The treaty softens the overlap. |
None of this is unusual for a cross-border specialist. All of it is easy to get wrong for an advisor who works on one side only.
Which direction you’re moving matters
Cross-border isn’t one specialty. Moving from Canada to the US raises departure tax, the RRSP, TFSAs and Canadian funds. Moving from the US to Canada raises the Roth election, US citizenship-based filing, and US estate exposure. Advisors usually know one direction best. Ask which.
What to ask a cross-border advisor
- Are you registered in both countries, or do you work with a partner firm? Who is responsible for which accounts?
- Which direction of move do you handle most?
- How would you treat my RRSP, TFSA or Roth given where I’ll live?
- Do you prepare tax returns, or work with a preparer who files on both sides?
- How do you coordinate with estate attorneys in each country?
On Wellspent, the cross-border specialty page lists the fee-only advisors who name US–Canada work on their own site, and each record shows their registration and the situations they handle. For where they’re based and what they charge, read how to find a cross-border financial advisor.