Retirement accounts do not automatically keep identical tax treatment after a cross-border move. The treaty can provide important coordination, but the result depends on the plan type, residence, citizenship, contribution history, distributions, and elections.
Inventory every plan separately
- RRSP and RRIF accounts
- Registered pension plans and pooled plans
- Traditional, rollover, and Roth IRAs
- 401(k), 403(b), and other employer plans
- Canadian and U.S. social-security benefits
- Non-registered annuities and deferred-compensation arrangements
Canadian plans held by U.S. taxpayers
IRS Revenue Procedure 2014-55 generally provides automatic treaty deferral for eligible U.S. citizens and residents with certain Canadian retirement plans until a distribution occurs and removed a former annual election form. That relief does not answer every income, basis, FBAR, Form 8938, beneficiary, or distribution question.
U.S. plans held by Canadian residents
Canada generally reports foreign pension income in Canadian dollars, subject to treaty provisions and available deductions. The treatment of an IRA distribution, Roth IRA, conversion, rollover, or employer-plan contribution can differ. Post-move Roth contributions can be particularly important under the treaty definition.
Cross-border contribution relief
Article XVIII contains limited rules that may recognize contributions to a qualifying retirement plan in the other country for employees on temporary assignments. Conditions include prior participation, employment relationships, time limits, and restrictions on simultaneous plan benefits.
Plan before distributions or rollovers
- Confirm tax residence and citizenship at the transaction date.
- Separate contributions, earnings, and previously taxed basis.
- Estimate source-country withholding and residence-country tax.
- Review foreign tax credit timing.
- Check whether a direct rollover is recognized in both countries.
- Keep historical statements and exchange-rate support.
Frequently asked questions
Is an RRSP automatically tax-deferred for a U.S. taxpayer?+
Revenue Procedure 2014-55 provides automatic treaty deferral for many eligible taxpayers and plans, but reporting and distribution issues still need separate review.
Is a Roth IRA always tax-free after moving to Canada?+
No. Treaty treatment can depend on the account history and whether contributions were made while resident in Canada, among other facts.
Official sources
Use the government pages below to verify current instructions and requirements.
IRS Revenue Procedure 2014-55 ↗Canada Department of Finance: Article XVIII of the treaty ↗Bring the notice, return, or records to a focused consultation.
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