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Cross-border retirement accounts and pensions

RRSPs, RRIFs, TFSAs, and RESPs on a US return, IRAs and 401(k)s in Canada, CPP, OAS, and Social Security across the border, the totalization agreement, and treaty withholding rates.

29 guides, each written by a CPA licensed in the US and Canada.

Canadian Tax

Can You Hold US Stocks in a TFSA? The Withholding Tax You Can't Get Back

You can hold US stocks in a TFSA, but the 15% US withholding tax on dividends is trapped inside the account. There is no foreign tax credit to recover it.

Aug 24, 2026
Cross-Border

Canadian Employer Pension (DB/DC) Received in the US: How Is It Taxed?

If you worked for a Canadian employer and earned a pension (defined benefit or defined contribution), and you now live in the US.

Aug 21, 2026
Cross-Border

Canadian Employer Pension (RPP/LIRA): Commuted Value and Cross-Border Tax

Taking the commuted value of a Canadian employer pension when leaving for the US creates tax in both countries. Covers treaty provisions, foreign tax.

Aug 30, 2026
Cross-Border

Canadian RRSP and US Tax: How the IRS Treats Your RRSP

The US defers tax on growth inside a Canadian RRSP for most US citizens and residents under Rev. Proc. 2014-55, then taxes withdrawals. No Form 8891 or 3520; FBAR and 8938 apply.

Sep 4, 2026
Cross-Border

Canadian Tax on US Social Security Benefits: How Canada Taxes Your American Retirement Income

US Social Security paid to a Canadian resident is taxed only in Canada: the full benefit is included and 15% deducted (50% for some pre-1996 recipients). How it works.

Sep 4, 2026
Cross-Border

Cross-border RESP planning for US and Canadian families

How RESPs work across the US-Canada border: trust reporting, PFIC exposure, CESG grants, withdrawal tax, and planning strategies for cross-border families.

Aug 27, 2026
Cross-Border

Do I pay both US self-employment tax and CPP?

US self-employment tax is a US-person exposure: it generally reaches US citizens and US residents wherever they live. Covers key rules, filing.

Aug 7, 2026
Cross-Border

Does Canada Have Social Security? CPP, QPP and OAS

Yes, in two parts: the CPP (QPP in Quebec), paid from work contributions, and OAS, paid on years lived in Canada. How each is taxed when you cross the border, and the treaty rule.

Oct 24, 2026
Cross-Border

Does the OAS Clawback Apply If I Live in the US?

Under Article XVIII(1) of the Canada-US treaty, OAS paid to a US resident is taxable only in the US. The 15% withholding applies.

Aug 21, 2026
Canadian Tax

Form NR5: Lower Non-Resident Tax on Canadian Pensions

Form NR5 asks the CRA to cut non-resident tax on your Canadian pension, RRIF or RRSP payments because you'll file a section 217 return. Approval usually covers five tax years.

Oct 24, 2026
Cross-Border

How Are CPP and OAS Taxed if I Live in the US?

The US then treats them as if they were US Social Security, so at most 85% of the total lands in your US income. Covers key rules, filing requirements,.

Jul 24, 2026
Cross-Border

How do I get the 15% treaty rate, not 30%, withheld on my US IRA or 401(k) as a Canadian resident?

For a Canadian resident who isn't a US citizen or green-card holder, 15% applies only where the payment is periodic; a pre-tax lump sum stays at 30%.

Jul 24, 2026
Cross-Border

I moved out of California. Can it still tax my 401(k) and IRA withdrawals?

Under 4 U.S.C. 114, no state may tax the retirement income of someone who is neither its resident nor its domiciliary. Which plans count, and what your old state can still tax.

Aug 16, 2026
Cross-Border

OAS Clawback for Non-Residents and Cross-Border Retirees

Old Age Security (OAS) is a monthly pension paid by the Canadian government to most Canadians aged 65 and older, regardless of work history.

Aug 30, 2026
Cross-Border

Pension Income Splitting Cross-Border: Canada-US

The higher-income spouse can allocate up to 50% of qualifying pension income to the lower-income spouse, reducing the family's combined tax.

Aug 30, 2026
Cross-Border

RESP EAP Withdrawals Cross-Border: How Is the Educational Assistance Payment Taxed?

How an RESP educational assistance payment (EAP) is taxed in Canada and the US when the subscriber or the student is a US person, plus FBAR and Form 3520 reporting.

Aug 30, 2026
Canadian Tax

Retirement Compensation Arrangement: Cross-Border Tax

An RCA is employer-funded retirement savings taxed through a 50% refundable tax. Leave for the US and payouts face 25% Part XIII tax; a US citizen faces open 409A questions.

Oct 24, 2026
Cross-Border

Roth IRA in Canada: Does It Stay Tax-Free?

Usually, yes. A Roth IRA stays tax-free in Canada if you file the one-time treaty election with the CRA and put no new money in while you live here. Here's how each piece works.

Jul 27, 2026
Cross-Border

RRIF Minimum Withdrawal: Table, Rules and Cross-Border Tax

The RRIF minimum is the January 1 value times a factor: 1/(90 minus age) before 71, then a table up to 20%. How RRIF withdrawals are taxed in Canada and if you live in the US.

Aug 30, 2026
Cross-Border

RRSP vs 401(k): How They Compare Across the Border

An RRSP and a 401(k) both defer tax until you withdraw. Compare 2026 limits, early withdrawal rules, forced withdrawals, and what happens to each when you cross the border.

Aug 24, 2026
Canadian Tax

RRSP Withdrawal Withholding Tax: Residents vs Non-Residents

RRSP withholding is 10%, 20% or 30% for Canadian residents (different in Quebec) and 25% for non-residents. For residents it's a prepayment. Here's the final tax on each side.

Oct 24, 2026
Cross-Border

RSP vs RRSP: Are They the Same Thing?

RSP and RRSP both refer to Canada's registered retirement savings plan. The difference in naming, the US tax treatment, and the cross-border complications.

Aug 30, 2026
Cross-Border

Social Security and CPP: How the US-Canada Totalization Agreement Prevents Double Social Security Tax

Without the Totalization Agreement, a worker who crosses the Canada-US border could owe social security contributions in both countries.

Sep 4, 2026
Cross-Border

TFSA vs Roth IRA: Is a Roth the US Equivalent of a TFSA?

The Roth IRA is the closest US equivalent of a TFSA: after-tax money in, tax-free growth and withdrawals. 2026 limits, withdrawal rules, and why neither crosses the border cleanly.

Aug 24, 2026
Cross-Border

The WEP Repeal: Do I Get More Social Security Now?

The WEP reduced your Social Security benefit if you received a pension from employment not covered by Social Security (including CPP).

Aug 21, 2026
Cross-Border

US Social Security Benefits Received in Canada: How Are They Taxed?

US Social Security paid to a Canadian resident is taxable only in Canada under the treaty. Canada includes it all, then allows a 15% deduction (50% for some pre-1996 recipients).

Aug 21, 2026
Cross-Border

US-Canada Totalization Agreement: how do I combine work credits for Social Security and CPP?

How the totalization agreement prevents double FICA and CPP contributions, assigns coverage to one country, and lets you combine work credits for benefits.

Aug 18, 2026
Canadian Tax

What Is an RRSP? RSP Meaning, Contribution Rules, and How It Works

An RRSP is a tax-deferred retirement account in Canada. Contributions are deductible, growth is sheltered, and withdrawals are taxed as income.

Aug 24, 2026
Cross-Border

When Should I Claim CPP vs Social Security? A Dual-Country Timing Strategy

If you worked in both Canada and the US, you may be entitled to benefits from both CPP and Social Security. your health.

Aug 21, 2026

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