Key Financial Differences: US vs Canada
| Factor | United States | Canada |
|---|---|---|
| Currency | USD | CAD (~$0.73 USD) |
| Income tax (top rate) | 37% federal + state | 33% federal + 13-25% provincial |
| Income tax (middle class) | 22-24% federal | 20.5-29% federal |
| Sales tax | 0-10% (state) | 5-15% (GST/HST) |
| Capital gains tax | 0-23.8% | 50% inclusion (effectively ~25%) |
| Healthcare cost | $5,000-$15,000/year (insurance) | $0 (basic); $2,000-$5,000 supplemental |
| 401k/RRSP limit | $23,500 (401k, 2025) | $32,490 (RRSP, 2025) |
| IRA/TFSA limit | $7,000 (IRA, 2025) | $7,000 (TFSA, 2025) |
| Social security/CPP | Social Security | CPP + OAS |
| Property tax | 0.5-2.5% | 0.5-1.5% (generally lower) |
| Student loan interest | Often 5-8% | Often 5-8% (federal Canada loans are 0% interest as of 2024) |
Cross-Border Tax Obligations
If You’re a US Citizen Living in Canada
| Obligation | Details |
|---|---|
| File US tax return (1040) | Yes — worldwide income, every year, forever |
| File Canadian tax return | Yes — Canadian resident, worldwide income |
| Foreign Earned Income Exclusion (FEIE) | ~$130,000+ of earned income excluded from US tax |
| Foreign Tax Credit (FTC) | Claim Canadian taxes paid against US tax |
| FBAR (FinCEN 114) | Report all foreign accounts with $10,000+ aggregate |
| FATCA (Form 8938) | Report specified foreign financial assets |
| Canadian TFSA | The US does not recognize TFSA tax-free status — gains are US-taxable |
| Canadian RRSP | US recognizes under tax treaty (tax-deferred) |
| Canadian mutual funds | Classified as PFICs — punitive US tax treatment |
| US accountant | Essential — need cross-border tax specialist ($500-$2,000/year) |
If You’re a Permanent Resident (Not US Citizen)
| Obligation | Details |
|---|---|
| US tax return | Not required after becoming non-resident |
| Canadian tax return | Yes — worldwide income |
| 401k/IRA | Leave in US; withdraw under normal rules |
| US rental property | Report in Canada; claim foreign tax credit |
| US Social Security | May still be eligible to collect at retirement |
| Filing | Much simpler than US citizens in Canada |
Critical Warning: PFICs (Passive Foreign Investment Companies)
| Issue | Details |
|---|---|
| What are PFICs? | Canadian mutual funds and ETFs (including those held in RRSP/TFSA) |
| US tax impact | Extremely punitive — excess distribution rules or QEF/Mark-to-Market elections |
| Solution | Hold US-listed ETFs (VTI, VT, BND) instead of Canadian mutual funds/ETFs |
| TFSA + PFIC double problem | TFSA gains are US-taxable AND Canadian ETFs in TFSA are PFICs |
| Best practice | US citizens should avoid TFSA entirely; use RRSP (treaty-protected) |
What Happens to Your US Accounts
| Account | When You Move to Canada |
|---|---|
| 401(k) | Leave it. Continue to grow tax-deferred. Withdraw at 59.5+ (or earlier with penalty). |
| Traditional IRA | Leave it or consolidate. Continue tax-deferred. |
| Roth IRA | Canada recognizes under treaty (if election made). Stop contributing after becoming Canadian resident. |
| HSA (Health Savings Account) | Canada does not recognize. Don’t contribute after becoming Canadian resident. Can still use for US medical expenses. |
| 529 Education Plan | Canada does not recognize tax-free status. Consider using before moving. |
| US brokerage (stocks) | Can usually keep. Some brokers restrict non-resident accounts. Notify broker of address change. |
| US bank accounts | Keep at least one for receiving SSA, managing US investments. |
| US credit score | Does not transfer to Canada. Build Canadian credit from scratch. |
Canadian Accounts to Open
| Account | Purpose | Details |
|---|---|---|
| Chequing account | Daily banking | Newcomer packages available |
| HISA (high-interest savings) | Emergency fund | EQ Bank, Wealthsimple (4%+) |
| RRSP | Retirement savings | US-treaty recognized; use US-listed ETFs if US citizen |
| TFSA | Tax-free savings | Avoid if US citizen (PFIC issues) |
| FHSA | First home savings | Only if planning to buy in Canada |
| RESP | Children’s education | CESG grants; US citizens face PFIC issues |
Building Canadian Credit
| Step | Timeline | Details |
|---|---|---|
| 1. Get SIN | Week 1 | Required for everything |
| 2. Newcomer credit card | Week 1 | CIBC, TD, RBC offer newcomer cards |
| 3. Amex Global Transfer | Week 1 | Transfer US Amex history to Canadian Amex card |
| 4. Phone/utility in your name | Month 1 | Builds credit |
| 5. Use credit card responsibly | Monthly | Under 30% utilization, pay in full |
| Expected Canadian score (1 year) | 700+ (especially with Amex transfer) |
The American Express Global Transfer is the best hack — it transfers your US credit history to a new Canadian Amex card, giving you a head start.
Healthcare Differences
| Service | US | Canada |
|---|---|---|
| Doctor visit | $150-$400 (without insurance) | $0 |
| Emergency room | $1,000-$5,000+ | $0 |
| Surgery | $10,000-$100,000+ | $0 |
| Prescription drugs | Expensive without insurance | Not covered (private insurance or pocket) |
| Dental | Not covered by most plans | Not covered (private insurance) |
| Mental health | Copays, limited sessions | Partially covered (limited sessions) |
| Wait times | Low | Can be longer for specialists |
| Monthly premium | $300-$800/person | $0-$75/month (BC only has premium) |
| Annual healthcare cost | $5,000-$15,000 | $0-$3,000 (supplemental only) |
Cost of Living Comparison
| Item | US (Average) | Canada (Average) | Difference |
|---|---|---|---|
| Rent (1-bed, city) | $1,500-$2,500 | $1,500-$2,500 | Similar (varies by city) |
| Groceries | $300-$500 | $400-$700 | 15-25% more in Canada |
| Gas (per litre) | $0.75-$1.10 | $1.40-$1.80 | 40-60% more in Canada |
| Internet | $50-$80 | $50-$100 | Slightly more in Canada |
| Cell phone | $30-$80 | $40-$80 | Similar |
| Car insurance | $100-$250/month | $150-$350/month | More in Canada (varies by province) |
| Healthcare (insurance) | $300-$800/month | $0 (public) | Major savings |
| Post-secondary tuition | $10,000-$60,000/year | $6,000-$12,000/year | Much cheaper in Canada |
US Social Security from Canada
| Situation | Details |
|---|---|
| Worked 10+ years in US (~40 credits) | Eligible for US Social Security |
| Canada-US Social Agreement | Can combine US and Canadian work credits for eligibility |
| Payments delivered to Canada | SSA can deposit to US bank account |
| Tax treatment | Report as foreign pension on Canadian return; foreign tax credit |
| WEP (Windfall Elimination Provision) | May reduce US SSA if also receiving CPP |
| Medicare coverage | Not available if living in Canada — use provincial healthcare |
Recommended Financial Setup
| Timeline | Action |
|---|---|
| Before moving | Find a cross-border tax accountant; do not sell Roth IRA |
| Week 1 | SIN, bank account, phone, Amex Global Transfer |
| Month 1 | Start building Canadian credit; set up HISA |
| Month 1-3 | Review 401k options (leave, consolidate, or convert) |
| Month 3-6 | Open RRSP (with US-listed ETFs if US citizen) |
| First spring | File BOTH US (1040) and Canadian tax returns |
| Year 1+ | Apply for credit products, FHSA if buying home |
| Ongoing | File US + Canadian taxes annually if US citizen |
Cross-Border Financial Professionals
| Professional | Why You Need Them | Cost |
|---|---|---|
| Cross-border tax accountant | File US + Canadian returns correctly | $500-$3,000/year |
| Cross-border financial planner | RRSP/401k/IRA optimization | $2,000-$5,000 (one-time plan) |
| Immigration lawyer | Status, work permits | $500-$5,000 |
| Currency strategy | Efficient USD/CAD transfers | Use Wise or IBKR for best rates |