The Modern Shift Podcast

US-Canada Cross-Border Retirement and Tax Planning


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This episode provide a detailed cross-border comparison of retirement savings vehicles in Canada and the United States, focusing heavily on tax implications for dual citizens and expats. Key Canadian accounts examined are the Registered Retirement Savings Plan (RRSP) and the Tax-Free Savings Account (TFSA), which are directly compared to American counterparts like the Traditional and Roth IRAs and the 401(k). The information highlights that while both countries offer similar tax-deferred growth accounts, the Canadian system is generally considered more generous and complex tax-treaty elections are required for U.S. persons holding Canadian plans, especially the TFSA, which the IRS does not recognize as tax-exempt. Furthermore, the sources caution against directly transferring funds between U.S. and Canadian accounts like IRAs and RRSPs due to potential withholding taxes and loss of contribution room. Advice is consistently given to those moving between countries to seek out cross-border financial advisors and accountants to navigate the intricate reporting requirements and avoid penalties.

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The Modern Shift PodcastBy abdelhamid bou ikhessayen