Relocating, whether within Canada or to the U.S., involves significant financial, legal, and lifestyle adjustments. This guide highlights the most critical factors to consider when planning your move. While this is not an exhaustive list and may not apply to every individual or household’s unique circumstances, the chart below is designed to spark additional ideas and provide a helpful broad-based starting point.
| Category |
Inter-Provincial Move (Within Canada) |
Relocation to the U.S. |
| Tax Residency |
Taxed based on primary residence as of December 31. Provincial tax rates and credits vary (e.g., Quebec – highest, Alberta – lowest). |
Maintain Canadian tax residency until significant ties are severed. U.S. residency may trigger dual taxation, mitigated through tax treaties. |
| Departure Tax |
Not applicable. |
Upon ceasing Canadian tax residency, a deemed disposition is triggered on most assets, potentially resulting in capital gains taxes, with exceptions for Canadian real estate and RRSPs. |
| Immigration Status |
Not applicable. |
Obtain appropriate visa (e.g., TN, H-1B). Visa type determines work eligibility and length of stay. |
| Employment & Income |
Income taxed at new provincial rates. Benefits and compensation vary by province. |
Apply for a U.S. Social Security Number (SSN). U.S. tax rates, deductions, and employer benefits vary by state. |
| Health Insurance |
Enroll in the new province’s health plan (waiting periods may apply, e.g., 3 months in Ontario). |
Provincial health care is lost. Secure private U.S. health insurance. Re-enrollment in Canadian healthcare may be delayed upon return. |
| Estate & Succession Planning |
Update your will to comply with new provincial laws. Probate fees and inheritance rules vary. |
U.S. estate tax applies to worldwide assets for residents. Update estate plans to minimize tax exposure. |
| Registered Accounts |
No changes required. |
RRSPs remain tax-deferred but reportable to the IRS. TFSAs and FHSAs are not U.S.-recognized—closure recommended before departure. |
| Trusts & Trustees |
Trusts remain under Canadian taxation, but new residence of trustees/beneficiaries may affect reporting. |
U.S. residency of trustees may trigger U.S. tax exposure and complex cross-border compliance requirements. |
| Holding Companies |
Federal taxation with provincial variations. Reporting may change depending on the new province. |
Complexities with non-resident shareholders. Potential U.S. filings—cross-border tax advice is essential. |
| Banking & Finances |
Canadian banking remains unaffected, though some banks are provincial (e.g., Van City). |
Need to establish U.S. banking relationships, build U.S. credit history, and obtain U.S. credit cards. |
| Currency Exchange |
Not typically applicable. |
Consider strategic CAD-to-USD conversion to minimize currency exchange losses. |
| Housing & Real Estate |
Factor in realtor fees, land transfer taxes, and moving expenses. |
Selling/renting Canadian property as a non-resident can create tax implications. U.S. property ownership may trigger U.S. estate taxes. |
| Lifestyle Considerations |
Research cost of living, cultural differences, and public services in the new province. |
Consider healthcare, cost of living, cultural adjustments, and proximity to family. State-specific customs may impact daily life. |
| Professional Guidance |
Consult local tax professionals and financial advisors to optimize strategies. |
Engage cross-border tax advisors, immigration lawyers, and financial planners. Leverage Canada-U.S. tax treaties to avoid double taxation. |
Final Thoughts
When considering a move, especially across borders, professional advice is critical. Tax residency, healthcare, estate planning, and cross-border compliance are complex and can significantly impact your financial well-being.
Interested in Learning More?
Northwood is a professional, boutique firm that specializes in serving the needs of families of wealth with a personal touch. Contact us to start a conversation.
Lauren Ambrosetti
Lauren is a member of Northwood’s family office advisory and investment teams, working with families in the areas of financial planning, investment management, and taxation.
