Do Canadians pay taxes in both Canada and the US?

It depends on your residency status. If you are a Canadian resident working temporarily in the US, you may owe taxes in both countries — but the Canada-US tax treaty prevents double taxation through foreign tax credits. If you become a US resident (e.g., green card or substantial presence test), you file a US return on worldwide income and claim a foreign tax credit for any Canadian taxes paid.

What visa do Canadians need to work in the US?

Common US work visas for Canadians include the TN visa (USMCA/NAFTA professionals — easiest, no petition needed, 63 eligible occupations), H-1B (specialty occupation, employer-sponsored, lottery system), L-1 (intra-company transfer), and O-1 (extraordinary ability). Canadians can also pursue green cards (permanent residence) through employer sponsorship or family ties.

Can I keep my RRSP and TFSA if I move to the US?

You can keep your RRSP — the Canada-US tax treaty allows it to grow tax-deferred in the US (but you must file IRS Form 8891 or make a treaty election). Your TFSA, however, is not recognized by the US. The US will tax your TFSA earnings annually as if it were a regular taxable account. Many cross-border advisors recommend collapsing your TFSA before becoming a US resident.

Working in the US as a Canadian 2026: Tax, Visa & Financial Guide

US Work Visa Options for Canadians

Visa Type	Best For	Duration	Employer Sponsorship?	Difficulty	Annual Cap
TN (USMCA)	63 listed professions	3 years (renewable)	Yes (job offer needed)	Easy	No cap
H-1B	Specialty occupations (bachelor’s+)	3+3 years	Yes	Hard (lottery)	65,000 + 20,000 (master’s)
L-1A	Intra-company managers/executives	7 years max	Yes (same employer)	Moderate	No cap
L-1B	Intra-company specialized knowledge	5 years max	Yes (same employer)	Moderate	No cap
O-1	Extraordinary ability (arts, science, business)	3 years (renewable)	Yes	Moderate-Hard	No cap
E-2	Treaty investors ($100K+ investment)	2 years (renewable)	Self-sponsored	Moderate	No cap
H-1B1	Specialty occupations (Chile/Singapore only)	18 months	Yes	N/A for Canadians	N/A
Green card	Permanent residence	Permanent	Usually yes	Hard (years-long)	Varies

TN Visa: Eligible Professions (Selected)

Category	Professions
Business	Accountant, management consultant, economist
Computing	Computer systems analyst, software engineer
Engineering	Engineer (all disciplines), architect
Healthcare	Pharmacist, veterinarian, medical technologist
Science	Mathematician, statistician, biologist, chemist
Education	College/university teacher, research assistant
Law	Lawyer (must be member of state bar)
Other	Technical writer, graphic designer, librarian

US Tax Obligations for Canadians

Residency Status & Tax Filing

Status	Who	US Tax Filing	Canadian Tax Filing
Canadian resident, working temporarily in US	Short-term assignment, commuter	US return on US-source income	Canadian return on worldwide income (foreign tax credit for US tax)
US resident (substantial presence test)	In US 183+ days using the formula	US return on worldwide income	Canadian return (if still CRA-resident) or departure return
US resident (green card holder)	Permanent resident	US return on worldwide income	Canadian return (if still CRA-resident) or departure return
US citizen (naturalized)	After citizenship	US return on worldwide income (forever)	Canadian return only if CRA-resident

Substantial Presence Test

Year	Days in US	Multiplier	Counted Days
Current year	120 days	× 1	120
Previous year (year −1)	120 days	× 1/3	40
Year −2	120 days	× 1/6	20
Total	—	—	180 (< 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.

Tax Comparison: Same Salary in Canada vs US

Metric	Canada ($100K CAD, Ontario)	US ($73K USD equiv., California)	US ($73K USD, Texas)
Federal tax	$14,800	$9,200	$9,200
Provincial/state tax	$5,800	$3,200	$0
CPP/Social Security	$4,300	$5,600	$5,600
EI/Medicare	$1,000	$1,060	$1,060
Total tax	$25,900 (25.9%)	$19,060 (26.1%)	$15,860 (21.7%)
Healthcare cost	$0 (included)	$3,000–$6,000/yr	$3,000–$6,000/yr
Tax + healthcare	$25,900	$22,060–$25,060	$18,860–$21,860

Cross-Border Financial Planning

RRSP: US Tax Treatment

Scenario	US Tax Treatment	Action Needed
Contributions (while Canadian resident)	Not deductible in the US	No US benefit
Growth (while US resident)	Tax-deferred (treaty election required)	File IRS Form 8891 or include in treaty-based return position
Withdrawals (while US resident)	Taxable in US as ordinary income; taxable in Canada (15% withholding)	Foreign tax credit to avoid double tax
Best strategy	Keep RRSP, let it grow tax-deferred; withdraw in retirement when in lower tax bracket	Consider converting to IRA (very complex, consult cross-border advisor)

TFSA: US Tax Treatment

Scenario	US Tax Treatment
While US resident	IRS does not recognize TFSA — all earnings taxed annually
PFIC implications	If TFSA holds mutual funds or ETFs, US anti-deferral rules (PFIC) create punitive taxation
Reporting	FBAR (FinCEN 114) + Form 8938 reporting required if balance exceeds thresholds
Best strategy	Collapse TFSA before becoming a US tax resident

RESP: US Tax Treatment

Scenario	US Tax Treatment
While US resident	IRS does not recognize RESP; earnings taxed annually
CESG (government grants)	May be considered taxable income by IRS
PFIC implications	Same as TFSA — mutual fund holdings create complexity
Best strategy	Consult cross-border advisor; may need to collapse or restructure

Feature	Canada (CPP/OAS)	US (Social Security)
Qualifying for benefits	Need 10 credits (10 years)	Need 40 credits (10 years)
Totalization agreement	✅ Combines CPP + SS years to qualify	✅ Combines SS + CPP years to qualify
If you worked in both countries	May receive partial CPP + partial SS	May receive partial SS + partial CPP
Taxation of benefits	CPP/OAS taxed differently in each country	SS benefits taxed at 0–85% in US; taxed in country of residence (treaty)

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

Benefit	Eligibility	Estimated 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

Moving Checklist: Canada to US

Task	Timeline	Details
Obtain work visa/authorization	1–6 months before	TN, H-1B, L-1, or green card
File Canadian departure return (T1)	Before/at departure	Report worldwide income to departure date
Deemed disposition of assets	At departure	Capital gains on stocks, investment property (not RRSP, RRIF, principal residence)
Notify CRA of departure	After leaving	Update address and residency status
Collapse TFSA	Before departure	Avoid US PFIC/tax issues
Open US bank account	After arrival	Need US address and SSN/ITIN
Apply for SSN	After arrival with work visa	Required for employment and tax filing
Transfer funds	As needed	Use Wise, OFX, or bank wire for best exchange rates
Set up US health insurance	Before/at employment start	Through employer or ACA marketplace
Update investment accounts	As needed	Canadian brokerages may restrict US residents
Get a cross-border tax advisor	Before departure	Essential for first filing year

Key Cross-Border Tax Filing Requirements

Form	Who Files	What It Reports	Threshold
IRS Form 1040	US residents	US worldwide income	All US residents
IRS Form 1040-NR	Non-residents with US income	US-source income only	Any US income
FBAR (FinCEN 114)	US persons	Foreign bank accounts	>$10,000 aggregate at any time
IRS Form 8938	US residents	Foreign financial assets	>$50,000 (single) at year-end
IRS Form 8891	US residents with RRSP	RRSP treaty election	Any RRSP held
CRA T1 (departure)	Departing Canadian residents	Final Canadian tax return	All departing residents
CRA T1 (ongoing)	Canadians with CDN income	Canadian-source income while non-resident	If receiving CDN income
CRA NR4	CDN payers to non-residents	Withholding on RRSP, rental income, pensions	Automatic on CDN-source payments