International Tax
US Tax Attorney for Americans in Canada
Canada is home to one of the largest US citizen expatriate populations in the world — including dual citizens who may never have filed US returns, Green Card holders who moved to Canada, and US-Canada cross-border families with assets on both sides of the border. The US-Canada tax treaty is helpful, but it does not eliminate all filing obligations.
Key US Tax Issues for Canada
Canadian TFSA Accounts
Tax-Free Savings Accounts (TFSAs) are entirely tax-sheltered under Canadian law. For US persons, TFSA income is fully taxable and the funds inside may be PFICs. Reporting is complex and often missed by US taxpayers in Canada.
RRSP and RRIF
US treatment of Canadian registered retirement savings plans is more favorable — the US-Canada treaty allows deferral of RRSP income. However, contributions and withdrawals require proper elections and disclosure to maintain treaty benefits.
FBAR for Canadian Accounts
Canadian bank accounts, brokerage accounts, and registered plans (TFSA, RRSP, RESP) that exceed the $10,000 aggregate threshold require FBAR filing annually.
Dual Citizenship Issues
Many people born in Canada to American parents — or Americans who became Canadian citizens — are US citizens without knowing it. US citizenship-based taxation means they owe US returns going back years.
Cross-Border Real Estate
US citizens selling Canadian real estate must report the sale and recognize any gain on their US return. The principal residence exemption under Canadian law does not eliminate US tax obligations.
Common Questions
Is my Canadian TFSA taxable in the US?
Yes. The US-Canada treaty does not protect TFSA income from US taxation. All income earned inside a TFSA — interest, dividends, capital gains — is reportable annually on your US return.
Does my RRSP get US tax deferral?
Generally yes — under Article XVIII(7) of the US-Canada treaty, US persons can elect to defer US tax on RRSP income until withdrawal. This election must be made each year on the return.
I was born in Canada but have a US parent — am I a US citizen?
Possibly. US citizenship can be transmitted through birth abroad to a US citizen parent under specific rules. If you are a US citizen, you have had US filing obligations your entire life — the Streamlined Foreign Offshore Procedures may allow you to catch up with zero penalty.
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