6 Tips for Cross-Border Financial Planning in Canada and the US
Written by Tiffany Woodfield, CRPC®, CIM®, Dual-Licensed Financial Advisor
Reading Time: 3 minutes
When you plan a move from the US to Canada or vice versa, it's important to get the financial planning steps right. As a dual-licensed financial advisor, I've helped many people successfully manage their investments as they move across the border. Based on this experience, here are my top five tips for planning your finances and taking care of your investments when moving across the border.
This article is not intended to provide legal or tax advice; it is general in nature. You need to speak to a qualified professional to understand your particular situation.
Tip 1 - Avoid a Tax Hit By Doing Your Tax Planning in Advance
To avoid a surprise tax hit, do your tax planning in advance. Arrange a pre-move consultation with a cross-border accountant and a cross-border financial advisor.
Discuss your specific situation, such as the investments you own in registered plans such as IRAs and 401(k)s versus open or non-registered accounts. Discuss your business and personal property details and how this will be impacted when you cross the border.
Tip 2 - Consider Investment Management to Prevent Your Assets from Being Frozen
There are so many moving parts when considering a cross-border move. You may not have considered the investment management of your assets. Because of regulatory rules, most investment advisors are not licensed to manage your investments once you cross the border. This results in the assets in your 401(k) or IRA being either frozen or not actively managed.
Typically as soon as you update your address to a Canadian one, you will receive a letter stating you have 30-60 days to find another advisor or liquidate your account. It would be best if you met with a dual-licensed advisor before you move, so you can begin planning how to manage your US and Canadian investments.
Tip 3 - Stay Onside with the IRS
Working with a professional team who understands both sides of the border allows you to stay onside with the IRS and avoid costly mistakes.
The Canada-US Income Tax Treaty is designed to ensure that one country's resident is not taxed on the same income in the same year as the other country. You don't have to be worried about having a huge tax burden when you move as long as your ducks are in a row.
As a US citizen or green card holder, you are required to file an annual tax return with the IRS on your worldwide income regardless of where you live. Working with a cross-border accountant and dual-licensed financial advisor will prevent you from having any issues with the IRS.
Tip 4 - Work with a Cross-Border Wealth Management Firm If Your Assets Are Over $1,000,000
With more wealth, the complexities of a cross-border move increase. You need to understand the options available to you to avoid a surprise taxable event. Having a team who knows how to make your cross-border move smoother will save you time in the long run.
Some of things to consider are:
- The location of your assets and where you are considered a permanent resident.
- If you a US person or on a working visa?
- Whether you have an estate and financial plan that takes into consideration income and assets in both countries.
- Have you considered how to transfer your wealth to beneficiaries?
Tip 5 - Estate Planning: Avoid Using a Non-Resident as the Executor of Your Will
Estate planning between Canada and the US adds additional complexity. As a Canadian resident, you should speak with a lawyer about updating your will for Canada. This is important as you likely won’t want to use a non-resident as the executor of your will. This is because the CRA may determine it as a non-resident trust, and you could face double taxation.
Having a revocable living trust in the US once you move to Canada may add additional complexities. At Raymond James, we offer trust services to help clients who need an executor, trustee and/or a power of attorney.
Please note that before you start any estate planning, you should always consult with a lawyer to understand your particular situation.
Tip 6 - Are you a Covered or Non-Covered Expatriate?
When moving, one additional consideration is whether you will renounce your US citizenship or (as a long-term green card holder*) give up your visa status. You need to determine the following: if you expatriate from the US are you considered a covered or non-covered expatriate?
If you are covered, you may be required to pay the exit tax and will need to do exit tax planning for the complicated tax consequences. This tax considers that all assets are sold the day before you gave up your US citizenship or terminated your visa.
Please speak to your cross-border accountant to determine if you are a Covered or Non-covered Expatriate and to do your tax planning.
*Long-term green card holder is if you held a green card for 8 of the last 15 years
Covered vs Non-Covered Expatriate
Next Steps
If you’re planning a cross-border move or you’ve already moved from the US to Canada and need help simplifying and optimizing your finances, then please get in touch. At SWAN Wealth we specialize in cross-border financial planning and wealth management. We would be happy to ensure that you’re onside with the IRS while protecting your investments and retirement assets.
More Cross-Border Financial Planning Articles & Guides
If you’re planning a cross-border move, these articles and guides will help you simplify your move and make sure you’ve got everything covered.
Roth IRA Canada - How to Manage Your Investments Across the Border
The Ultimate Financial Planning Resource for Dual Citizens or Green Card Holders Living in Canada
Retiring to Canada - A Financial Planning Guide
Financial and Tax Planning for US Citizens Living in Canada
Canadian RRSP Facts for Dual Citizens, Expats and Canadians
About the Author
Tiffany Woodfield is a dual-licensed financial advisor and the co-founder of SWAN Wealth Management, along with her husband, John Woodfield. Tiffany specializes in advising clients who live both in Canada and the United States and need to simplify their cross-border financial plan, move their assets across the border, and optimize their investments so they can minimize their tax burden. Together Tiffany and John Woodfield help their clients simplify their cross-border finances and create long-term revenue streams that will keep their assets safe whether they live in Canada or the US.
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Information in this article is from sources believed to be reliable, however, we cannot represent that it is accurate or complete. It is provided as a general source of information and should not be considered personal investment advice or solicitation to buy or sell securities. The views are those of the author, SWAN Wealth Management, and not necessarily those of Raymond James Ltd. Investors considering any investment should consult with their Investment Advisor to ensure that it is suitable for the investor’s circumstances and risk tolerance before making any investment decision. Raymond James Ltd. is a Member - Canadian Investor Protection Fund. Raymond James (USA) Ltd., member FINRA/SIPC. Raymond James (USA) Ltd. (RJLU) advisors may only conduct business with residents of the states and/or jurisdictions for which they are properly registered.
