Cross-Border Financial Planning for Canada/US in 2026
The Ultimate Financial Planning Resource For Dual Citizens or Green Card Holders Living in Canada
Written by Tiffany Woodfield, CRPC®, CIM®, TEP®, Senior Financial Advisor, Associate Portfolio Manager
When you're moving from the United States to Canada, you need to have a solid cross-border financial plan in place well before your move date.
As soon as you know that you're going to move across the border, begin the cross-border financial planning process. Create a short list of cross-border advisors and book a call to find out more about their services and who they help.
When you work with a Canada/US dual-licensed financial advisor, they can provide investment management and financial planning services whether you live in Canada or the US. It's never too early to get started. However, if you leave everything to the last minute, you may lose out on significant tax savings.
I recommend that you start the process 1-2 years in advance because this gives you greater tax planning opportunities.
This guide will give you a thorough overview of the cross-border financial landscape. But it's no substitute for first-person advice. Be sure to book an appointment with a cross-border advisor and accountant at your earliest possible convenience so you can identify areas of priority importance.
Table of Contents
Basics of Cross-Border Financial Planning
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Start Early: Begin your cross-border financial planning 1–2 years in advance because it allows you to minimize tax liabilities and avoid costly missteps.
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Understand the Tax System: Canada and the US have different tax laws, tax rules, and reporting obligations. Working with a cross-border advisor and accountant will help you avoid unexpected tax bills or penalties. Some tax complexities are inevitable, but planning well in advance can prevent double taxation.
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Work with a Dual-Licensed Advisor: Choose a wealth management firm whose financial advisors are licensed in both Canada and the US. This ensures your foreign financial assets are properly managed and compliant under both tax regimes. A dual-licensed advisor can manage your investments whether you live in the US or Canada.
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File Your US Tax Returns: US citizens and Green Card holders must file annual US tax returns to report their worldwide income, even while living in Canada. This includes reporting foreign financial institutions and accounts.
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Plan for RRSPs and IRAs: Canadian RRSPs and US IRAs have different contribution rules and tax treatment. Strategic coordination is critical to preserve tax deferral and avoid triggering unexpected income inclusion.
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Avoid PFICs: Most Canadian mutual funds and ETFs are considered Passive Foreign Investment Companies (PFICs) by the IRS. Holding these investments can result in punitive taxation and complex reporting for US taxpayers. You should avoid investing in PFICs as a US person in Canada. In addition, always consult with a dual-licensed advisor before investing in Canadian funds.
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File the FBAR: If your combined foreign financial assets exceed US$10,000, you must file the FBAR. Indeed, failing to do so can lead to substantial penalties.
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Be Cautious with TFSAs and RESPs: While popular in Canada, TFSAs and RESPs may be treated unfavorably under US tax rules. Always consult a cross-border advisor before opening or contributing to these accounts.
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Plan Your Estate in Both Countries: US citizens living in Canada need to consider both countries’ estate tax rules, including the US Lifetime Tax Exclusion, and how tax treatment differs between countries. In addition, it is easier if Canadian residents appoint a trustee who lives within their province or territory of residence in Canada to avoid complications. Of note is the fact that trusts are treated differently in the US and Canada, so working with a TEP, a lawyer, and a cross-border financial advisor is critical.
12 Keys to Cross-Border Financial Planning and Investing for Americans, Dual Citizens, and Canadians Moving Back to Canada
1. Find an advisor who is dual licensed
Working with a dual Canada/US licensed advisor means you don’t have to liquidate your US brokerage accounts or 401(k) and IRAs when you move across the border.
Your US advisor isn’t licensed to help you once you live in Canada. Since the (FATCA) Foreign Account Tax Compliance Act came into legislation, the IRS has been increasing their enforcement of rules around foreign investments and bank accounts.
Even updating a phone number can trigger a letter from your US advisory firm stating you have 30-60 days to find another advisor or you will be forced to liquidate.
2. Consolidate your 401(k), 403(b), or 457
You can consolidate your 401(k), 403(b), or 457 by rolling over into an IRA and having it managed from Canada.
If you keep your plan in the US, after moving to Canada, those accounts cannot be actively managed, and often, you cannot even see the holdings. It's hard to reach your financial goals if you can't see your investment and retirement accounts. When you have one advisor managing the full picture, it will be easier to understand your investment strategy and plan income streams for the future.
Rolling over your 401(k) to an IRA and having it managed from Canada with a dual-licensed financial advisor may be an optimal solution. But keep in mind there are some benefits an employer plan offers that an IRA doesn’t.
3. Transferring an IRA into an RRSP is possible, but it’s not the best solution
Transferring an IRA into an RRSP becomes complicated due to withholding taxes in the US and then having to top up the RRSP with funds from other sources.
If an individual cannot top up the RRSP from other sources they will be taxed as income inclusion on the difference between the IRA value and the amount contributed to the RRSP. Also make sure you plan to move to Canada permanently if you do this as you cannot move RRSPs to IRAs.
In addition, IRAs may be considered a superior retirement vehicle as you can stretch out the tax liability longer because you keep the tax deferral status for multiple beneficiaries. In Canada, an RRSP can maintain the tax deferred status only when rolled over to your spouse. For any other beneficiaries, taxes are paid out of the estate, before the beneficiaries receive any inheritance.
4. Speak to your accountant before you consider opening an RESP or TFSA
As a US person, you have additional filing obligations when investing in RESPs or TFSAs.
If you have a non-US person as a spouse, you can put it in their name. However, this only works if the US taxpayer is filing a “Married Filing Separate” US tax return. If they file a “Married Filing Jointly” tax return, the Canadian spouse's income is also reported 100% on the joint US tax return.
Commonly used Canadian mutual funds and ETFs are considered Passive Foreign Investment Companies (PFICs) to the IRS. Investments characterized as PFICs are subject to strict and complicated tax guidelines. This means extra filing for an American or green card holder and potential negative tax implications. Working with a dual licensed investment advisor allows you to avoid these issues.
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5. Contributing to an IRA while living in Canada may not be possible
In general a Canadian taxpayer would not make a contribution to an IRA or 401(k) unless the contribution is deductible for Canadian tax purposes.
Contributions to a US employer plan may be deductible if this individual is temporarily working in Canada and participates in a retirement plan offered by their US employer. There are certain conditions that must be met to make a tax deductible claim.
6. Using an alternate US address when living in Canada
If you reside in Canada and provide your US investment firm an alternate address of a friend or relative in order to keep the IRA, it is against SEC guidelines.
It is only a matter of time before the IRS will determine where you actually reside. In addition, it can cause state tax issues when you take out RMDs.
7. Social Security can be decreased when you receive CPP
Because of the Windfall Elimination Provision (WEP), your social security may be reduced if you are receiving the Canada Pension Plan (CPP).
Still it’s good to claim for both CPP and WEP as it does not create a negative overall result.
Also the WEP applies to your own US social security, but if collecting spousal benefits, WEP doesn’t apply if the spouse isn’t collecting CPP.
It's important to understand how Social Security works.
You are fully insured if you worked 40 quarters (10 years) of employment in the US. You get 4 credits a year.
You are currently insured if you earned at least 6 credits during the previous 13 quarter periods. If you are currently living in the US, go to the SSA website to apply for a social security online account giving you access to statements, changing your address or applying for benefits.
If you already reside in Canada, you can go to the links below to get information on your social security.
The Social Security retirement age has changed.
Congress passed a law to increase the full retirement age from age 65 up to age 67, depending on the year you were born.
To be entitled to full benefits from social security, you need to reach your FRA (full retirement age).
8. Canadian mutual funds and ETFs are considered PFICs
A PFIC is a Passive Foreign Investment Company where the company earns 75% or more of its gross income from non-business operational activities or at least 50% of its assets are used to produce passive income.
It is common for a US person to unknowingly hold PFICs. Most Canadian financial advisors don’t realize the negative implications of holding these investments and invest their US clients’ money in them. Common PFICs are Canadian mutual funds, Canadian ETFs, RESPs and TFSAs. Investing in a PFIC causes complicated reporting by your accountant and is taxed punitively.
9. Inherited IRAs can still benefit from tax-deferred growth
If you are living in Canada and inherit an IRA, you can roll it over to an inherited IRA with a dual licensed financial advisor and continue the tax deferred growth for up to 10 years (or longer if an Eligible Designated Beneficiary, see SECURE Act below).
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10. You should know about the SECURE Act update
The SECURE Act became law in December of 2019.
The SECURE Act was created to make it easier for Americans to save money for retirement by allowing them to contribute more money to tax-advantaged savings plans and increasing the RMD (Required Minimum Distributions) age. Essentially, this act extended the tax benefits for a longer period.
Prior to the SECURE Act, non-spouse beneficiaries of IRAs could spread the distributions from an inherited IRA over their lifetime. Currently, all funds must be distributed by the end of the 10th year after the account owner's death unless the beneficiary is an EDB (Eligible Designated Beneficiary).
Surviving spouses, disabled persons, chronically ill persons, a beneficiary not more than 10 years younger than the decedent, or the decedent’s minor child are all EDBs. You don't need to take any money out during years 1-9, but the account needs to be emptied by the end of year 10. There are a few exceptions to the new rule.
There was a SECURE ACT 2.0, which passed in 2022 and added more provisions.
Some highlights are the increased age at which individuals must take RMDs, the removal of RMDs for Roth accounts in employers' plans, and an increase in catch-up provisions for older workers.
If you’re a business owner, I recommend reviewing this page from the IRS: SECURE 2.0 Act Info for Businesses from the IRS.
11. Retain tax-free growth of your IRA
A Roth IRA is like a TFSA in Canada, and if you stop contributing, you can retain tax-free growth status.
To keep the tax-free growth status of your Roth IRA, you shouldn’t contribute to the account once you reside in Canada.
If you follow these rules, your income and withdrawals are not taxable in Canada. However, if you do contribute, you lose the tax-free status and reporting the income earned and capital gains in Canada is complicated.
12. You can contribute to an RRSP while living in Canada
As a US person living and working in Canada, you can earn room in an RRSP.
It is recognized by the Canada/US Income Tax Treaty and therefore you get a deduction from your current taxes when you contribute. The growth and earnings within the account aren’t taxable. To confirm your contribution room, look at statements on CRA My Account.
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8 Tax Planning Tips for Dual Canada-US Citizens
1. For estate planning, you should know about the Unified Gift & Estate Tax Exemption
You can optimize your estate to prevent excessive taxation. Estate tax is a levy on an estate based on the current value of the assets.
An estate only pays tax if the value is worth more than the unused US gift and estate exclusion. This exclusion typically changes each year.
The US Lifetime Gift and Estate Tax exclusion is US$15,000,000 per person in 2026, with annual inflation adjustments thereafter and no scheduled sunset. US citizen spouses together may leave up to US$30,000,000 to beneficiaries without triggering estate tax.
Your estate would get a greater than 40% tax rate for the amount above this exclusion amount. Also, assets in the estate tax base are still entitled to a free step-up in basis (ACB). So beneficiaries inheriting assets may never have to pay capital gains tax on the assets they inherit.
2. Take advantage of gift tax exclusions
Annual gift tax exclusion is US $15,000 per donee with no limit of the number of recipients or US $157,000 to a non-US citizen spouse like a Canadian.
You are required by law to report the gift even when you don’t owe money. This amount doesn’t affect the lifetime exemption.
3. Include your FBAR (Report of Foreign Bank and Financial Accounts) when reporting income
As a US person, you have to report your worldwide income and you need to report any foreign bank accounts if the aggregate total exceeds US$10,000 at any time during the year.
Many clients think if they don’t have $10,000 in a particular account they don’t have to report but if all your accounts added together are over $10,000 at any point you have to report all accounts. There are penalties if you fail to comply.
4. Certain investments are taxed favourably in Canada, while others are taxed favourably in the US
First, make sure your financial advisor knows how your investments are taxed in Canada and the US.
Canada has a higher tax regime than the US. To encourage Canadian residents to invest in Canada, the CRA taxes dividends from Canadian companies favorably. As a US resident, municipal bonds may help to save state tax, but the interest is taxable when you reside in Canada.
5. Exchange rates are significant and can cause unexpected tax bills
On your US tax return, you have to report gains and losses in US dollars.
Just because you have a loss in one currency does not mean that it will be the case in another currency. This mismatch could result in an unexpected tax bill. Having an advisor who has the ability to offer investments in CDN or US currency means you aren't constrained by the foreign exchange.
6. Capital gains are taxed differently in Canada and the US
In Canada, capital gains are the difference between purchase price and the sale price.
Only half of your capital gain is taxed, regardless of how long you owned it. In the US, capital gains are either short-term or long-term. If the holding period was one year or less, it's considered short-term and is taxed as ordinary income.
Conversely, if the holding period was greater than a year, the gain is subject to lower tax rates that would more closely resemble the tax-favored capital gains treatment in Canada.
7. Tax-loss selling can allow you to minimize your tax burden, but the rules are different in Canada and the US
The concept with tax-loss selling is that you sell the investments you've lost money on to offset the gains that you’ve realized. You only pay tax on the net amount of gain.
In the US and Canada, these gains are treated differently. You cannot carry back capital losses in the US, but in Canada, you can carry back 3 years and carry forward indefinitely. In the US, you can carry forward a tax loss to future years to offset a profit. In addition, in the US, losses that exceed the capital gain can be used to offset ordinary income up to $3000 in any one year.
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8. Selling a home can have tax implications that should be considered in advance
As a US citizen, if you sell your home, whether you are living in Canada or the US, there is an exclusion on the capital gain of up to US$250,000 if single or US$500,000 if married and filing jointly.
If the capital gain is more than these amounts, tax is owed on the additional gain.
To get this exemption you need to have lived in the home two of the past 5 years. Whereas, if living in Canada, as a Canadian citizen, you don’t pay tax on the gain in your principal residence.
Estate Planning for Dual Citizens in Canada
1. Do not use a non-resident as executor of your will
If you are residing in Canada and have a US resident as the executor of your will, the CRA may determine the estate is resident in the US.
This is based on the fact that the decision maker lives in the US. For tax purposes, it is then seen as an offshore trust and double taxation applies through CRA and the IRS. (Speak to a cross-border lawyer before you name the executor of your will.)
2. US Trusts are not beneficial to Canadian residents
Having a US trust while a resident in Canada isn’t a good idea.
From a Canadian tax perspective, the trust is likely considered a Canadian resident trust because the trustees are now Canadian residents. Meaning you will have to file a T3 tax return. It can also cause double taxation.
This information is general in nature and should not be construed or relied upon as legal, tax or accounting advice. We recommend clients seek independent advice from a professional advisor before acting on such information. Please consult with your accountant or lawyer for information on your specific situation.
🔎 Case Study: Helping a Cross-Border Couple Retire to Canada After Selling Their Business
Selling a Business and Getting Ready to Move to Canada
When Mark and Laura* first reached out to SWAN Wealth, they were in their late fifties, living in Washington State, and feeling increasingly unsettled by the political climate in the United States. They had always planned to retire in Canada, where Mark was born, but recent changes pushed them to move up their timeline.
They were about to sell their healthcare-related business for over $6 million, and they needed help managing the proceeds in a way that supported both their retirement goals and their planned move back to Canada in 2026. Most of their wealth had been tied up in that business, and they didn’t want to make any wrong moves.
Mark & Laura’s Cross-Border Challenges
Mark and Laura’s challenges were typical of many cross-border families and included:
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How to manage and transfer US retirement accounts such as SEP IRAs and Roth IRAs, without triggering unnecessary tax.
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How to plan for Canadian tax residency and the sale of their US home.
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How to structure income and investments so their assets would be ready for the move.
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How to navigate university tuition for their dual-citizen daughter, who hoped to attend UBC in Vancouver.
Mark and Laura are intelligent, thoughtful, and proactive.
But like many entrepreneurs who have sold a business, they didn’t want to manage their investments and retirement planning on their own. They wanted a single team that could coordinate investments, taxes, and cross-border planning to ensure a smooth transition.
The Solution and Process
The first step was to help Mark and Laura consolidate and simplify.
They had roughly $4 million spread between two large US brokerage firms. Mark originally felt safer diversifying across custodians, but after our discussions, he understood that true diversification comes from a well-structured portfolio, not from using multiple firms.
We began transferring their accounts to our cross-border platform so that we could:
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Move their SEP IRAs into portfolios that maintained tax-deferred status while they remained US residents.
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Replace US mutual funds and municipal bonds (which are considered PFICs and can create tax issues in Canada) with a globally diversified portfolio that could be easily managed once they become Canadian residents.
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Maintain accurate cost bases and position tracking to avoid double taxation on future gains.
Together with our tax team, we reviewed their S Corp and LLC to confirm what needed to be dissolved and what could remain open until after their move. We also coordinated with their US accountant to ensure any business losses would be handled properly and to confirm what could (and could not) be carried forward to Canada.
On the personal side, we addressed their questions about their daughter’s tuition. Because UBC’s tuition for Canadian residents is about one-third of the international rate, we explored how establishing Canadian residency before his second year could reduce the family’s overall costs.
Finally, we completed a comprehensive financial plan to help them see how their assets could sustain their lifestyle for life. This plan covered:
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Future housing and healthcare costs.
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Timing their move to minimize currency risk.
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Cash-flow projections to ensure they would never run out of money.
Why It Worked
This multi-step process worked because everything was coordinated under one roof. Mark and Laura no longer had to juggle multiple advisors who didn’t understand both sides of the border.
They now have:
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Integrated cross-border tax planning that addressed their business sale, future residency, and ongoing filing obligations.
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A disciplined investment strategy based on ETFs and direct holdings rather than high-fee mutual funds.
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A single, trusted advisory team to manage both the financial and emotional aspects of their transition.
Mark was initially concerned about “gambling” in the market. But that feeling eased once he saw that our approach focuses on quality, long-term holdings (companies he could actually own), not speculation.
The Outcome
By late 2025, SWAN Wealth had successfully transitioned much of Mark and Laura’s portfolio to the new structure and completed their financial projections.
They were comfortable and confident with the plan.
They told us they finally felt they could sleep well at night. They knew their investments were properly diversified and ready for the move, their tax situation was under control, and their long-term spending plan was clear.
Mark remained eager to begin the next chapter of their lives in Canada, while Laura appreciated that the plan allowed them to move thoughtfully — balancing financial security with family timing.
They both expressed that they felt “in good hands.”
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*The case studies and client examples presented on this website are for informational purposes only. Names and identifying details have been changed to protect client confidentiality. These examples are based on real scenarios but do not constitute financial advice. Individual circumstances vary, and you should consult a qualified financial advisor before making any financial decisions.
Common Questions
Our job is to provide our cross-border clients with the knowledge and tools to manage their money effectively so they can comfortably live the life they want. Our approach includes staying informed on the ever-evolving laws in Canada and the US affecting estate planning, gifting, and investment regulations.
Yes, at SWAN Wealth, we offer Canadian and US currency investment strategies whether you live in Canada or the US. This means you won't be forced to liquidate funds when you move across the border because they are in a different currency.
Yes, it is essential to have advice for tax and estate planning, and this is even more crucial when you are a cross-border client because you must consider the implications of two countries.
If you are looking for a one-time financial plan, they won't offer wealth management services, which can limit you because you won't have the complete offerings and guidance needed to stay on track to reach your goals.
Yes, because of regulations, most investment advisors cannot manage accounts for non-residents unless they are dual-licensed. Additionally, an unregistered investment account is a taxable account, which means there are extra complexities that need to be planned for to avoid tax consequences.
Tax efficiency is crucial when doing cross-border financial planning because you must consider how each country and state will treat income, distributions, gifting, and estate planning.
There are different tax consequences for various retirement accounts. In general, it is safe to invest in an RRSP if you have contribution room, but a TFSA and RESP need to be considered carefully as they may have negative tax outcomes.
While Canada has a higher tax regime than the US, there are planning opportunities to help reduce the cost.
All investing involves risk. However, as a dual citizen or US person living in Canada, it's important to be aware of the tax traps a cross-border client can inadvertently fall into.
John Woodfield of SWAN Wealth Management is a CFP and a dual-licensed advisor. To find cross-border CFPs, look for cross-border advisory firms online. Then view the credentials of their team members and founders.
Next Steps:
Simplify Your Cross-Border Financial Transition
If you would like to speak with a Cross-Border Financial Advisor in order to simplify and optimize your cross-border financial plan, please schedule a call by clicking the link here.
About the Author
Tiffany Woodfield is a dual-licensed financial advisor and the co-founder of SWAN Wealth Management, along with her husband, John Woodfield.
Tiffany specializes in advising clients who live both in Canada and the United States and need to simplify their cross-border financial plan, move their assets across the border, and optimize their investments so they can minimize their tax burden.
Together Tiffany and John Woodfield, CFP and Portfolio Manager, help their clients simplify their cross-border finances and create long-term revenue streams that will keep their assets safe whether they live in Canada or the US.
Information in this article is from sources believed to be reliable; however, we cannot represent that it is accurate or complete. It is provided as a general source of information and should not be considered personal investment advice or solicitation to buy or sell securities. The views are those of the author, SWAN Wealth Management, and not necessarily those of Raymond James Ltd. Investors considering any investment should consult with their Investment Advisor to ensure that it is suitable for the investor's circumstances and risk tolerance before making any investment decision. Raymond James Ltd. is a Member of the Canadian Investor Protection Fund. Raymond James (USA) Ltd., member FINRA/SIPC. Raymond James (USA) Ltd. (RJLU) advisors may only conduct business with residents of the states and/or jurisdictions for which they are properly registered.
