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Working in the US as a Canadian: Tax, Visa & Financial Guide

Updated

Working in the US means dealing with two tax systems at once: the US decides whether you are a US tax resident by its own tests, while Canada keeps taxing you as long as you stay a Canadian resident. This guide covers the visas, the US residency tests, cross-border filing and how the US treats RRSPs, TFSAs and RESPs. It is part of the international and cross-border tax guides; whether you remain a Canadian resident is covered in am I a Canadian tax resident.

US Work Visa Options for Canadians

Visa TypeBest ForDurationEmployer Sponsorship?DifficultyAnnual Cap
TN (USMCA)63 listed professions3 years (renewable)Yes (job offer needed)EasyNo cap
H-1BSpecialty occupations (bachelor’s+)3+3 yearsYesHard (lottery)65,000 + 20,000 (master’s)
L-1AIntra-company managers/executives7 years maxYes (same employer)ModerateNo cap
L-1BIntra-company specialized knowledge5 years maxYes (same employer)ModerateNo cap
O-1Extraordinary ability (arts, science, business)3 years (renewable)YesModerate-HardNo cap
E-2Treaty investors ($100K+ investment)2 years (renewable)Self-sponsoredModerateNo cap
H-1B1Specialty occupations (Chile/Singapore only)18 monthsYesN/A for CanadiansN/A
Green cardPermanent residencePermanentUsually yesHard (years-long)Varies

TN Visa: Eligible Professions (Selected)

CategoryProfessions
BusinessAccountant, management consultant, economist
ComputingComputer systems analyst, software engineer
EngineeringEngineer (all disciplines), architect
HealthcarePharmacist, veterinarian, medical technologist
ScienceMathematician, statistician, biologist, chemist
EducationCollege/university teacher, research assistant
LawLawyer (must be member of state bar)
OtherTechnical writer, graphic designer, librarian

US Tax Obligations for Canadians

Residency Status & Tax Filing

StatusWhoUS Tax FilingCanadian Tax Filing
Canadian resident, working temporarily in USShort-term assignment, commuterUS return on US-source incomeCanadian return on worldwide income (foreign tax credit for US tax)
US resident (substantial presence test)In US 183+ days using the formulaUS return on worldwide incomeCanadian return (if still CRA-resident) or departure return
US resident (green card holder)Permanent residentUS return on worldwide incomeCanadian return (if still CRA-resident) or departure return
US citizen (naturalized)After citizenshipUS return on worldwide income (forever)Canadian return only if CRA-resident

Substantial Presence Test

YearDays in USMultiplierCounted Days
Current year120 days× 1120
Previous year (year −1)120 days× 1/340
Year −2120 days× 1/620
Total180 (< 183 = non-resident)

If total ≥ 183, you are a US tax resident. The closer-connection exception may still help if your ties to Canada are stronger.

While you remain a Canadian resident, Canada taxes your US pay as part of your worldwide income and credits the US tax against it.

Comparing the tax bill

How much of a salary goes to tax differs between a Canadian province and a US state, and US payroll taxes and health insurance change the comparison. Side-by-side figures for the same income are in the Canada vs USA tax comparison.

Cross-Border Financial Planning

RRSP: US Tax Treatment

ScenarioUS Tax TreatmentAction Needed
Contributions (while Canadian resident)Not deductible in the USNo US benefit
Growth (while US resident)Tax-deferred (automatic under the treaty since 2014)No annual election or filing needed; disclose on FBAR/FATCA if thresholds are met
Withdrawals (while US resident)Taxable in US as ordinary income; taxable in Canada (15% withholding)Foreign tax credit to avoid double tax
Common approachKeep RRSP, let it grow tax-deferred; withdraw in retirement when in lower tax bracketConverting to an IRA is possible but very complex; cross-border advice is common

TFSA: US Tax Treatment

ScenarioUS Tax Treatment
While US residentIRS does not recognize TFSA; all earnings taxed annually
PFIC implicationsIf TFSA holds mutual funds or ETFs, US anti-deferral rules (PFIC) create punitive taxation
ReportingFBAR (FinCEN 114) + Form 8938 reporting required once balances pass the reporting thresholds
Common approachCollapse TFSA before becoming a US tax resident

RESP: US Tax Treatment

ScenarioUS Tax Treatment
While US residentIRS does not recognize RESP; earnings taxed annually
CESG (government grants)May be considered taxable income by IRS
PFIC implicationsSame as TFSA: mutual fund holdings create complexity
Common approachCross-border advice; the plan may need to be collapsed or restructured

Social Security & Retirement

US citizens and green card holders who later live in Canada keep filing in the US; FBAR, FATCA and PFIC rules for that group are covered in the dual citizenship tax guide.

Canada-US Social Security Agreement

FeatureCanada (CPP/OAS)US (Social Security)
Qualifying for benefitsCPP: no minimum, based on actual contributions. OAS: 10 years of Canadian residency after age 18 for a partial pensionNeed 40 credits (10 years of work)
Totalization agreement✅ Combines CPP + SS years to qualify✅ Combines SS + CPP years to qualify
If you worked in both countriesMay receive partial CPP + partial SSMay receive partial SS + partial CPP
Taxation of benefitsCPP/OAS taxed differently in each countrySS benefits taxed at 0–85% in US; taxed in country of residence (treaty)

Example: 15 Years Working in Canada, 10 Years in US

BenefitEligibilityEstimated Amount
CPP (15 years of credits)✅ Qualifies~$550/month (partial)
OAS (15 years in Canada)✅ Qualifies (partial if lived in Canada 20+ years by 65)~$350/month (partial, 15/40)
US Social Security (10 years)✅ Qualifies (40 credits)~$800/month (partial)
Total retirement income~$1,700/month

How US Social Security is taxed once you are back in Canada is covered in foreign pension income and Canadian taxes.

Moving Checklist: Canada to US

Moving to the US for good also ends Canadian residency, with a departure tax on most investments; the leaving Canada tax checklist covers that side.

TaskTimelineDetails
Obtain work visa/authorization1–6 months beforeTN, H-1B, L-1, or green card
File Canadian departure return (T1)Before/at departureReport worldwide income to departure date
Deemed disposition of assetsAt departureCapital gains on stocks, investment property (not RRSP, RRIF, principal residence)
Notify CRA of departureAfter leavingUpdate address and residency status
TFSA decision (many collapse it)Before departureUS PFIC/tax issues
Open US bank accountAfter arrivalNeed US address and SSN/ITIN
Apply for SSNAfter arrival with work visaRequired for employment and tax filing
Transfer fundsAs neededUse Wise, OFX, or bank wire for best exchange rates
Set up US health insuranceBefore/at employment startThrough employer or ACA marketplace
Update investment accountsAs neededCanadian brokerages may restrict US residents
Get a cross-border tax advisorBefore departureEssential for first filing year

Key Cross-Border Tax Filing Requirements

FormWho FilesWhat It ReportsThreshold
IRS Form 1040US residentsUS worldwide incomeAll US residents
IRS Form 1040-NRNon-residents with US incomeUS-source income onlyAny US income
FBAR (FinCEN 114)US personsForeign bank accounts>$10,000 aggregate at any time
IRS Form 8938US residentsForeign financial assets>$50,000 (single) at year-end
IRS Form 8938 (RRSP disclosure)US residents with RRSPRRSP reported as a foreign financial asset; tax deferral is automatic, no election form neededIf total foreign assets pass the Form 8938 threshold
CRA T1 (departure)Departing Canadian residentsFinal Canadian tax returnAll departing residents
CRA T1 (ongoing)Canadians with CDN incomeCanadian-source income while non-residentIf receiving CDN income
CRA NR4CDN payers to non-residentsWithholding on RRSP, rental income, pensionsAutomatic on CDN-source payments