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Cross-Border Mortgages: Canadians Buying Property in the US (2026)

Updated

Buying real estate in the US as a Canadian involves cross-border financing, currency considerations, and dual-country tax obligations. Here is a complete guide.

Financing options for Canadians

Option Down Payment Rate Complexity Best For
Cross-border bank (RBC, TD) 20%–30% US market rates (~6%–7.5%) Moderate Canadians wanting a familiar bank
US foreign national loan 25%–30% 6.5%–8.5% High No Canadian bank relationship
HELOC on Canadian property N/A (borrow equity) Canadian HELOC rate (6%–7%) Low Property paid for in cash using HELOC
Canadian lender (US property) 25%–35% Varies Moderate Select credit unions / trust companies
Private / hard money 30%–40% 9%–14% Low Fast close, credit challenges
All cash 100% N/A Lowest Simplest; most competitive offer

Cross-border mortgage programs

RBC Bank (Georgia, N.A.)

Feature Details
Who RBC’s US subsidiary — serves Canadians buying in the US
Down payment 20%–25%
Credit Uses Canadian credit history
States available Most US states (focus on Florida, Arizona, California, Hawaii)
Currency Mortgage in USD
Advantage Familiar institution; uses Canadian income documentation

TD Bank (US)

Feature Details
Who TD operates in the eastern US (Maine to Florida)
Down payment 20%–30%
Credit Can use Canadian credit history for TD clients
States available East coast — FL, NY, NJ, CT, MA, PA, NC, SC, VA, etc.
Currency Mortgage in USD
Advantage Existing TD clients may have streamlined process

Qualification requirements

Requirement Details
Down payment 20%–30% (foreign national)
ITIN Individual Taxpayer Identification Number — needed for most US mortgage applications
Income documentation Canadian Notice of Assessment, employment letter, or business financials
Credit Canadian credit report accepted by cross-border lenders; US credit may be needed for domestic US lenders
Debt ratios US DTI (Debt-to-Income) similar to Canadian TDS — typically max 43%
Reserves Many lenders require 6–12 months of mortgage payments in liquid reserves
Property type Single-family, condo, townhouse — condos must be “warrantable” (meets US lending standards)
US bank account Required for mortgage payments and property expenses

Currency considerations

Factor Details
Exchange rate risk Monthly USD mortgage payments fluctuate in CAD terms
Current rate (2026) ~$1.00 USD = $1.36–$1.40 CAD
Impact on $2,000 USD payment ~$2,720–$2,800 CAD per month (varies with exchange rate)
Hedging strategies Forward contracts, regular USD purchases, maintain US-dollar income
US bank account Keep a USD buffer to smooth out exchange rate fluctuations
When exchange hurts If CAD weakens, your effective mortgage cost rises
When exchange helps If CAD strengthens, your effective cost drops

Currency impact example

CAD/USD Rate $2,000 USD Monthly Payment in CAD Annual Cost in CAD
1.25 $2,500 $30,000
1.35 $2,700 $32,400
1.40 $2,800 $33,600
1.50 $3,000 $36,000

A 10% swing in the exchange rate changes your annual cost by ~$3,000 CAD.

Tax implications

US tax obligations

Tax Details
US income tax (rental income) Report on US tax return (Form 1040-NR); can elect to file under Section 871(d) to deduct expenses
State income tax Depends on state — Florida and Arizona have no state income tax
US property tax Varies by state, county, and municipality; typically 0.5%–2.5% of assessed value
FIRPTA withholding on sale 15% of gross sale price withheld at closing (refundable if tax owed is less)
US capital gains tax 15%–20% federal + state (if applicable)
US estate tax Applies to US-sited assets; $60,000 exemption for non-residents (Canada-US tax treaty increases this)

Canadian tax obligations

Tax Details
Report US rental income Include on your Canadian return; claim foreign tax credit for US tax paid
Report US property sale Include capital gains on Canadian return; foreign tax credit for US tax paid
Form T1135 Required if foreign property cost > $100,000 CAD — annual reporting
Principal residence exemption US property can be designated as PR for Canadian purposes — but you lose the exemption on your Canadian home for those years
Foreign tax credit The Canada-US tax treaty prevents double taxation — you claim credit for US taxes paid against your Canadian tax

US estate tax and the Canada-US tax treaty

Scenario US Estate Tax Exposure
US assets < $60,000 No US estate tax
US assets > $60,000 (no treaty benefit) 18%–40% estate tax on US-sited assets above $60,000
With treaty benefit Pro-rated US estate exemption ($13.61M in 2024, adjusted for inflation) — most Canadians with worldwide estates under ~$13.6M USD pay no US estate tax
Cross-border trust / entity May provide additional protection — consult a cross-border estate lawyer

Buying process for Canadians

Step Details Timeline
1. Get an ITIN Apply via IRS Form W-7 4–8 weeks
2. Open a US bank account RBC, TD, or a US bank that works with Canadians 1–2 weeks
3. Get pre-approved Cross-border mortgage or US foreign national program 2–4 weeks
4. Engage a realtor US-licensed realtor experienced with Canadian buyers Ongoing
5. Find a property Search, tour, make an offer Varies
6. Inspection, appraisal Home inspection, lender appraisal 1–3 weeks
7. Final mortgage approval Provide documentation, close the loan 3–6 weeks
8. Close Sign documents (may be done remotely via notary); funds wired in USD 1–2 weeks

Ongoing costs

Cost Florida Example Arizona Example
Property tax ~1.0%–1.5% of assessed value ~0.6%–0.8%
Homeowners insurance $2,000–$8,000+/year (hurricane risk) $800–$2,000/year
HOA / condo fees $200–$800/month (community dependent) $100–$400/month
Flood insurance (if required) $500–$3,000/year Rarely needed
Property management (if rented) 8%–12% of gross rent 8%–12% of gross rent
Maintenance 1%–2% of property value/year 0.5%–1.5% of property value/year
US tax preparation $500–$1,500/year $500–$1,500/year
Canadian cross-border tax prep $500–$1,500/year $500–$1,500/year

Checklist for Canadians buying in the US

  • Applied for an ITIN (IRS Form W-7)
  • Opened a US bank account (USD)
  • Pre-approved for cross-border or foreign national mortgage (or prepared to pay cash)
  • Engaged a US realtor experienced with Canadian buyers
  • Retained a cross-border tax advisor (familiar with both CRA and IRS)
  • Consulted a cross-border estate lawyer (US estate tax planning)
  • Purchased adequate US homeowners insurance
  • Set up a plan for currency exchange (regular transfers, forward contracts)
  • Budgeted for FIRPTA withholding on any future sale
  • Planned for Form T1135 reporting in Canada
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