The U.S.–Canada Cross-Border Financial Planning Guide for 2026–2027

The U.S. and Canada share a long border, an income tax treaty and a Social Security agreement. None of that makes a move simple. Each country decides for itself whether you're a tax resident. Canada taxes many of your assets on the way out, the U.S. keeps taxing its citizens wherever they live, and accounts that are tax-free on one side of the border often aren't on the other.

The short answer for most people is to settle three things before you move: your residency date in each country, any departure tax, and how each of your accounts will be treated on both sides. Most of the expensive mistakes are timing mistakes, and they're hard to undo afterward.

This guide covers the main financial issues for Americans moving to Canada, Canadians moving to the U.S. and Canadians who spend winters in the U.S. A transfer between Houston and Calgary within the energy industry is a typical example. It uses 2026 figures, the 2027 figures the IRS has already released, and the proposals in Canada's Budget 2026, which was tabled on November 5, 2026 and isn't law yet. Dollar amounts are U.S. dollars unless marked C$.

This is general education, not advice for your specific situation. Rules change, and cross-border cases depend heavily on the facts, so work with professionals who know both systems.

What are the key U.S. figures for 2026 and 2027?

These are the inflation-adjusted U.S. amounts that come up most often in a U.S.–Canada move.

Sources: Rev. Proc. 2025-32 for 2026 and Rev. Proc. 2026-35 for 2027.

What should I do with my accounts and property before I move?

Before you move, decide what to keep, what to close and what to sell. Those decisions have tax consequences in both countries, so make them before your residency changes.

Bank accounts

If you're moving permanently, it can make sense to consolidate in your new country. There are also good reasons to keep at least one account open in the country you're leaving:

• Family transfers are easier with an account in that country.
• Ongoing bills and investments, such as a rental property or a mortgage, are easier to manage locally.
• Credit history. If you move back, an established banking relationship can make loans easier to get.

When moving money out of the U.S., use bank-to-bank transfers. Starting January 1, 2026, a 1% federal tax applies to remittance transfers that the sender funds with cash, a money order, a cashier's check or a similar instrument (IRS). Transfers funded from a bank account or a U.S. debit or credit card aren't subject to it.

Investment and retirement accounts

Americans moving to Canada often keep their 401(k)s and IRAs in the U.S. Cashing out early can trigger U.S. income tax plus a 10% early-withdrawal penalty. Canada generally lets traditional IRAs keep growing tax-deferred, but a Roth IRA needs a one-time election and no further contributions, which is covered below. Many U.S. brokers also restrict or close accounts for clients with foreign addresses, so check your broker's policy before you move.

Canadians moving to the U.S. can generally leave an RRSP in place and keep its tax deferral for U.S. purposes. A TFSA is different, since the U.S. doesn't treat it as tax-free. Canadian mutual funds and ETFs held in a taxable account are generally passive foreign investment companies (PFICs) once you're a U.S. tax resident, with punitive U.S. tax treatment. Many Canadian firms also limit what they'll do for a client with a U.S. address, so ask yours what happens to each account before you go.

If you withdrew from your RRSP under the Home Buyers' Plan, you generally have to repay the balance within 60 days after you become a non-resident, or before you file that year's return if that's earlier, or the unpaid amount is added to your income (CRA).

Real estate and personal property

• A Canadian home you're leaving. Canada's principal residence exemption is limited by the number of years you were resident in Canada, so a home you keep after you leave can start building taxable gain (CRA Folio S1-F3-C2). Converting it to a rental is generally treated as a sale and repurchase at fair market value unless you elect to defer that. Once you're a non-resident, Canada withholds 25% of gross rent. You can elect to file a Canadian return and pay tax on the net amount instead, with any excess withholding refunded (CRA guide T4058).
• Selling Canadian real estate as a non-resident. You must notify the CRA no later than 10 days after the sale (CRA guide T4058). The buyer generally withholds 25% of the purchase price unless you obtain a certificate of compliance, which generally means paying 25% of the gain or posting security up front (CRA circular IC72-17R6). Start that process well before closing.
• A U.S. home you're leaving. You can exclude up to $250,000 of gain on your main home, or $500,000 on a joint return, if you owned and lived in it for at least two of the five years before the sale (IRS Topic 701). If you sell after you've stopped being a U.S. person, the buyer generally must withhold 15% of the sale price under the U.S. rules for foreign sellers of real estate (IRS). On the Canadian side, property you own when you become a Canadian resident is treated as acquired at its fair market value on that date, so Canada generally taxes only the growth after you arrive (CRA).
• Buying a home in Canada. People who aren't Canadian citizens or permanent residents are currently barred from buying residential property in Canada's cities and larger towns, with exceptions. Those include work permit holders with at least 183 days left on the permit who haven't bought another property during the ban, and purchases made with a spouse who is a Canadian citizen or permanent resident (CMHC). The ban runs to January 1, 2027, and Budget 2026 proposes extending it to January 1, 2029 for existing homes while exempting new ones (Budget 2026).
• Belongings. Decide what to sell, store or ship, and get moving quotes early.

Power of attorney

If you're leaving significant assets behind, appoint someone you trust under a power of attorney that's valid where the assets are. A U.S. power of attorney may not be accepted by a Canadian bank or land registry, or the reverse, and each province and state has its own requirements.

How are you taxed when you move between the U.S. and Canada?

What you owe, and to which country, depends on your citizenship, your residency in each country, the type of income and where your assets are. The U.S.–Canada income tax treaty prevents most double taxation, but it doesn't resolve every situation. The IRS also publishes the treaty documents and a plain-language summary in Publication 597.

Leaving Canada: the departure tax

When you stop being a Canadian resident, Canada generally treats you as having sold most of your property at fair market value on that date and taxes the gain (CRA). One-half of a capital gain is included in income. A proposed increase to that inclusion rate was cancelled in March 2025 (CRA).

The main exceptions and filing rules:

• What's excluded. Canadian real estate, Canadian business property, pensions, RRSPs, RRIFs, RESPs and TFSAs aren't treated as sold. Neither is property you already owned when you became a Canadian resident, if you were resident for 60 months or less during the previous 10 years. That last exception matters for Americans on a shorter Canadian assignment.
• Form T1161. If the fair market value of all the property you own when you leave is more than C$25,000, you list it on this form. Cash, registered plans and personal-use items worth less than C$10,000 don't count toward that total. The late-filing penalty is C$25 a day, up to C$2,500.
• Form T1243 reports the deemed sales and the resulting gains or losses.
• Form T1244 lets you defer paying the tax, without interest, until you actually sell. If the federal tax on the deemed sale is more than C$16,500, you have to give the CRA adequate security.

Because Canada taxes the gain when you leave and the U.S. taxes it later when you actually sell, the same growth can be taxed twice. The treaty lets a person who is taxed on a deemed sale in one country elect to be treated in the other country as having sold and repurchased the property at fair market value at that time (Article XIII of the treaty). Ask your U.S. preparer about that election for the year you move.

Your Canadian residency generally ends on the latest of the date you leave, the date your spouse and dependants leave, or the date you become a resident of your new country (CRA). You report world income for the part of the year you were resident. After that, Canada taxes only your Canadian-source income.

Leaving the U.S.: the expatriation tax

Moving to Canada doesn't trigger a U.S. exit tax by itself. The tax applies to U.S. citizens who renounce and to long-term green card holders who give up their status, if they're "covered expatriates" (IRS). A long-term resident is someone who held a green card in at least 8 of the last 15 tax years (Form 8854 instructions). You're a covered expatriate if any of these applies:

• Your average annual net income tax for the prior five years is more than $211,000 for 2026 or $218,000 for 2027.
• Your net worth is $2 million or more.
• You can't certify five years of U.S. tax compliance on Form 8854.

Covered expatriates are generally treated as having sold everything they own the day before expatriating. The first $910,000 of net gain is excluded for 2026 and $940,000 for 2027. Special rules apply to retirement accounts, deferred compensation and trusts.

Two points matter for Canadians in particular:

• Returning green card holders. A long-term green card holder who claims to be a Canadian resident under the treaty, doesn't waive treaty benefits and notifies the IRS is treated as having given up U.S. residency on that date. A treaty position meant to simplify your filing can therefore start the exit tax. Get advice before you take it.
• Dual citizens from birth. Someone who became a citizen of both countries at birth, is still a Canadian citizen and tax resident, and was a U.S. resident for no more than 10 of the last 15 tax years isn't a covered expatriate just because of the income tax or net worth tests. The five-year compliance certification still applies.

Who has to file where?

Americans in Canada. U.S. citizens and resident aliens abroad must file U.S. returns and report worldwide income wherever they live. Canada taxes based on residency, which turns on your residential ties: a home in Canada, a spouse or partner in Canada and dependants in Canada are the significant ones, with secondary ties such as personal property, bank accounts and a driver's licence also counting (CRA). If you stay 183 days or more in a year without those ties, you can be a deemed resident. You're generally a resident from the day you arrive to live in Canada, and you report world income from that date (CRA). Quebec residents also deal with Revenu Québec, which administers its own return.

Canadians in the U.S. You're a U.S. tax resident if you hold a green card or meet the substantial presence test. That means at least 31 days in the U.S. in the current year and at least 183 days over three years, counting all days this year, one-third of last year's days and one-sixth of the days from the year before that (IRS Topic 851). Canadians working in the U.S. in TN status, which is granted for up to three years at a time, usually meet that test. U.S. residents report worldwide income. Nonresidents are generally taxed only on U.S.-source income.

Once you're a non-resident of Canada, Canadian payers generally withhold 25% from Canadian-source interest, dividends, rent, pensions, Old Age Security, Canada Pension Plan benefits and RRSP or RRIF payments, and the treaty reduces that rate for many types of income (CRA guide T4058). Tell your Canadian financial institutions when your residency changes so they withhold correctly.

How do the rules work for Canadian snowbirds?

A Canadian who winters in the U.S. can become a U.S. tax resident without intending to. Because of the three-year formula, about four months a year, every year, is right at the line: 122 days in each of three years counts as 183.

If you meet the test, you can still be treated as a nonresident under the closer connection exception when all of these are true (IRS):

• You were in the U.S. fewer than 183 days during the year.
• You kept a tax home in Canada for the entire year and had a closer connection to Canada than to the U.S.
• You haven't applied for, or taken steps toward, a green card.

You claim it by filing Form 8840 by the tax return due date. If you don't file it on time, you generally can't claim the exception. If you spend 183 days or more in the U.S. in a single year, the exception isn't available and you'd need to rely on the treaty instead.

What if both countries say you're a resident?

If you're a tax resident of both countries in the same year, Article IV of the treaty settles it in this order:

1. Permanent home. You're a resident of the country where you have a permanent home available to you.
2. Centre of vital interests. If you have a permanent home in both countries, or in neither, you're a resident of the country with which your personal and economic relations are closer.
3. Habitual abode. If that can't be determined, you're a resident of the country where you have a habitual abode.
4. Citizenship. If you have a habitual abode in both or neither, you're a resident of the country of which you're a citizen.
5. Mutual agreement. If you're a citizen of both or neither, the two tax authorities settle it.

Canada treats a person who is a resident of another country under a treaty as a non-resident of Canada, which can trigger the departure tax described above. On the U.S. side, the tie-breaker generally doesn't release U.S. citizens from U.S. tax. The treaty's saving clause lets the U.S. tax its citizens as if the treaty didn't exist, with some exceptions. Claiming treaty residence on a U.S. return generally requires disclosure on Form 8833.

How do you avoid paying tax twice?

• Americans in Canada can claim the foreign tax credit for Canadian income tax, or exclude foreign earned income with the foreign earned income exclusion, up to $132,900 for 2026 and $137,300 for 2027. The two can be combined but not on the same income. Which one works better depends on your income, your province and whether you want to keep contributing to an IRA, so model both.
• Canadian residents with U.S. income, including Americans living in Canada, can generally claim Canada's federal foreign tax credit for U.S. tax paid on income that Canada also taxes, up to the limits.
• The 3.8% net investment income tax is a gap. On August 31, 2026, the Federal Circuit held in Estate of Bruyea v. United States that the treaty doesn't allow a foreign tax credit against this tax (opinion). A higher-income American in Canada can owe it on investment income that Canada has already taxed.
• Social Security and Canadian public pensions are taxed only in the country where you live. U.S. Social Security paid to a Canadian resident is taxed in Canada, with 15% of the benefit exempt (CRA), and U.S. citizens who are residents of Canada are exempt from U.S. tax on those benefits. Canada Pension Plan and Old Age Security benefits paid to a U.S. resident are taxed in the U.S. as if they were U.S. Social Security (IRS Publication 915).
• Working across the border. Under the treaty, pay for work performed in the other country is generally taxed only in your home country if it's $10,000 or less in the other country's currency. The same applies if you're present there no more than 183 days in a 12-month period and the pay isn't borne by an employer or permanent establishment there.

State income taxes don't always follow the treaty. California, for example, taxes RRSP earnings each year even though the federal treaty election defers them (FTB Publication 1001). Texas has no personal income tax, but when and how you establish residency still matters. See our guide to Texas residency planning.

The Social Security agreement

The U.S.–Canada Social Security agreement coordinates U.S. Social Security with the Canada Pension Plan and Old Age Security. A separate understanding covers the Quebec Pension Plan. It does two main things:

• Prevents double coverage. In most cases your work is covered by only one country's system, so you and your employer aren't paying into both for the same work. Self-employed people are generally covered where they reside.
• Combines work credits. If you don't have enough credits to qualify for a benefit in one country, credits from the other may be counted. You need at least six U.S. credits before Canadian credits can be counted toward a U.S. benefit. U.S. credits can count toward Old Age Security residence requirements and toward eligibility for some Canada Pension Plan benefits.

That matters for Old Age Security in particular. Someone living outside Canada generally needs at least 20 years of Canadian residence after age 18 to receive it abroad, compared with 10 years for someone living in Canada (Government of Canada).

Reporting foreign accounts: FBAR, Form 8938 and Form T1135

U.S. persons, including citizens, green card holders and others who are U.S. tax residents, must generally file an FBAR with FinCEN if the combined value of their foreign financial accounts exceeded $10,000 at any time during the year. That applies to Americans in Canada and to Canadians who become U.S. residents. Canadian bank and brokerage accounts count, and so do RRSPs and RRIFs, even though their income is deferred.

You may also need Form 8938 with your tax return. For a single filer living abroad, the threshold is more than $200,000 in specified foreign financial assets on the last day of the year or more than $300,000 at any time during the year. Thresholds are lower for people living in the U.S. Penalties for missing either form can be steep, even when no tax is owed.

Canada has its own form. Canadian residents file Form T1135 if the total cost of their specified foreign property was more than C$100,000 at any time in the year. You don't file it for the year you first become a Canadian resident, and personal-use property is excluded. For a newcomer, cost means fair market value on the date you became resident.

How does each account work on the other side of the border?

This is the least intuitive part of a U.S.–Canada move. Here's a summary, with detail below.

U.S. retirement accounts in Canada

Canada's tax law gives traditional IRAs a deferral similar to its own registered plans, so the growth generally isn't taxed in Canada until you withdraw (CRA Folio S5-F3-C1). A 401(k) is generally treated the same way. Withdrawals are taxable in Canada, with a credit for U.S. tax.

A Roth IRA needs action. Under the same CRA folio, income inside a Roth is taxable in Canada each year unless you file a one-time, irrevocable treaty election by the filing due date for the year you became a Canadian resident. With the election, distributions aren't taxed in Canada to the extent they wouldn't be taxed in the U.S. Any contribution made while you're a Canadian resident, including a conversion from a traditional IRA, ends the deferral for later growth. If a Roth conversion is part of your plan, do it before you become a Canadian resident.

Contributing from Canada has limits too. IRA contributions require taxable compensation, and income excluded under the foreign earned income exclusion doesn't count.

Canadian registered accounts in the U.S.

RRSPs and RRIFs. Income building up inside these plans would otherwise be taxable in the U.S. each year. Under Rev. Proc. 2014-55, eligible individuals are automatically treated as having made the treaty election to defer U.S. tax until distribution. You no longer file a special form for it. When you withdraw, Canada withholds non-resident tax. The treaty caps that at 15% for periodic pension payments, while a lump-sum withdrawal is generally subject to the full 25%. The U.S. taxes the distribution too, with a foreign tax credit for the Canadian tax. How much of a withdrawal is taxable in the U.S. depends on your U.S. basis in the plan, so have that calculated before a large withdrawal.

TFSAs. If you become a non-resident of Canada, you can keep your TFSA, and Canada won't tax its earnings or withdrawals. You won't earn new contribution room, and contributions made while you're a non-resident are taxed at 1% per month (CRA). The U.S. side is the problem. The IRS deferral for Canadian retirement plans doesn't extend to TFSAs, so most practitioners report TFSA income on the U.S. return each year. Whether a TFSA is also a foreign trust that requires Forms 3520 and 3520-A is unsettled. Rev. Proc. 2020-17 exempts certain tax-favored foreign savings trusts from that reporting, but it doesn't name the TFSA and it doesn't change the income tax treatment. Decide whether to keep a TFSA before you become a U.S. resident.

RESPs and FHSAs. These don't get treaty deferral in the U.S. either. An FHSA also requires Canadian residency through the home purchase for a qualifying withdrawal (CRA). Get advice on these accounts before you move, and before a U.S. citizen in Canada opens one.

Passive foreign investment companies (PFICs)

A foreign corporation is a PFIC if at least 75% of its income is passive, or at least half of its assets produce or are held to produce passive income. Most Canadian mutual funds and Canadian-listed ETFs fall into this category when held by a U.S. person in a taxable account. Without a qualified electing fund (QEF) or mark-to-market election, gains and certain distributions are taxed at the highest ordinary rate plus an interest charge. U.S. persons who own PFICs generally must file Form 8621 each year. For many Americans in Canada, the simpler approach is to hold individual shares, or U.S.-domiciled funds where permitted, rather than Canadian pooled funds.

Equity compensation and business interests

Stock options and RSUs are taxed differently in each country, and timing differs too. Which country taxes a grant depends on where you lived and worked between grant and vesting or exercise. Each country may tax a portion, so you'll often need sourcing calculations and foreign tax credits on both sides. Get a calculation done before you exercise or sell around a move.

If you own a business through an LLC, an S corporation or a Canadian corporation, get entity-specific advice before you move. The two countries can classify the same entity differently, and that can change who is taxed and when.

Which Budget 2026 proposals should you watch?

Canada's Budget 2026 includes several proposals that affect cross-border households (Budget 2026 tax measures). They're proposals until legislation passes.

• Form T1135. The filing threshold would rise from C$100,000 to C$200,000 for taxation years ending after 2026.
• Filing deadline. The personal return and balance-due date would move to May 15 for all individuals, starting with the 2027 tax year. Today it's April 30, with a June 15 filing date for the self-employed.
• Foreign buyer ban. The ban would be extended to January 1, 2029 for existing homes, with new homes exempted.

How should I manage currency exchange?

Costs of converting

The spread between a dealer's buy and sell price is a cost you pay every time you convert between U.S. and Canadian dollars. Airport kiosks and retail exchange counters are usually the most expensive. Banks and dedicated transfer services with transparent fees are usually cheaper, and larger transfers often get better rates. If you convert often, compare each provider's total cost, including the spread and fees.

Exchange-rate risk

If you earn in one currency and spend in another, exchange-rate swings change your real income and expenses. A large one-time conversion, such as house sale proceeds, can lose meaningful value if the timing is poor. A few ways to manage that:

• Match currencies. Where practical, hold assets in the currency of your future spending, such as a home purchase or retirement income.
• Stage large conversions over time rather than converting everything on one day.
• Hedge with care. Currency hedging can reduce volatility but has costs and complexity. Get advice before using it.

Currency also affects taxes. The U.S. measures gains and losses in U.S. dollars and Canada measures them in Canadian dollars, so the same sale can show a gain in one country and a loss in the other. In Canada, an individual's net foreign currency gain or loss for the year is reported only to the extent it's more than C$200 (CRA).

How does moving affect my estate plan?

An estate plan that works in one country may not work well, or at all, after a move. Your residency, your citizenship, where your assets are and where your beneficiaries live all matter. The two systems also tax death differently.

How each country taxes an estate

Canada has no estate or inheritance tax. Instead, a person who dies is treated as having sold their capital property at fair market value immediately before death, and the gain is taxed on the final return. Property left to a spouse or common-law partner who is a Canadian resident can generally pass on a tax-deferred basis (CRA).

The U.S. taxes the worldwide estates of its citizens and residents above the basic exclusion amount, which is $15 million per person for 2026 and $15,480,000 for 2027. A U.S. citizen living in Canada is subject to both systems. The treaty provides credits in each country for the other's tax at death, but the results depend on what you own and who inherits.

U.S. estate tax for Canadians with U.S. assets

A Canadian who isn't a U.S. citizen or resident can still owe U.S. estate tax on U.S.-situated assets. Those include U.S. real estate, such as a vacation home in Arizona or Florida, and stock of U.S. corporations, even when held in a Canadian brokerage account. The executor must file a U.S. estate tax return if those assets are worth more than $60,000 at death (IRS).

The treaty softens this in two ways:

• A pro-rated credit. The estate of a Canadian resident gets a share of the credit available to a U.S. citizen, based on the portion of the worldwide estate located in the U.S. In practice, a Canadian whose worldwide estate is below the U.S. exclusion amount generally won't owe U.S. estate tax. The estate still has to file and disclose worldwide assets to claim the credit.
• A small-estate rule. If the worldwide estate is $1.2 million or less, U.S. estate tax applies only to property whose gain the U.S. could have taxed under the treaty, which is mainly U.S. real estate.

Wills, trusts and directives

• Wills. Many people with assets in both countries use a separate will in each, with each will covering only the assets located there. The wills must be drafted together so one doesn't accidentally revoke the other. Tell both lawyers about both documents. If you have minor children, name guardians and think through where your children would live.
• Trusts. Trusts don't travel well. A U.S. revocable living trust can be taxed very differently under Canadian law once you or a trustee is a Canadian resident. A Canadian family trust can be a foreign trust for U.S. purposes, with complex reporting for U.S. beneficiaries. Have estate and tax lawyers in both countries review any trust before you create it or move with it.
• Advance directives. Health care directives and medical powers of attorney are governed by local law. Sign new documents that meet your new state's or province's requirements.

When one spouse isn't a U.S. citizen

• No unlimited marital deduction. Assets passing to a non-citizen surviving spouse generally don't qualify for the U.S. marital deduction unless they pass through a qualified domestic trust (QDOT). In many U.S.–Canada situations, the treaty offers an alternative marital credit that the executor can elect in place of the marital deduction.
• Jointly owned property. When a U.S. citizen dies owning property jointly with a non-citizen spouse, the full value is generally included in the citizen's estate unless the survivor can show their own contributions. Keep records of who paid for what.
• Gifts between spouses. Gifts to a non-citizen spouse qualify for an annual exclusion of $194,000 for 2026 and $201,000 for 2027, rather than the unlimited exclusion between citizen spouses (IRS). For gifts to anyone else, see how much you can give tax-free in 2026.

Inheritances

The U.S. doesn't tax a U.S. person who receives an inheritance from abroad. However, a U.S. person who receives more than $100,000 in gifts or bequests from a nonresident alien or foreign estate during the year must report them on Form 3520. That commonly applies to a U.S. resident who inherits from a parent in Canada. Canada doesn't tax the person who inherits either, since the tax is settled on the deceased's final return.

What insurance do I need after the move?

Insurance protects against medical costs, the loss of income from disability and the financial impact of a death. Moving countries can quietly leave gaps.

Health insurance

Americans moving to Canada. U.S. health plans generally won't cover you once you live in Canada, and Medicare usually doesn't cover care outside the U.S. (Medicare.gov). Canada's public system is run by the provinces. Citizens and permanent residents can apply for a provincial health card, and in some provinces you may wait up to three months for coverage to start, so buy private insurance for that gap (Government of Canada). Rules for work permit holders vary by province. In Alberta, for example, workers from outside Canada may be eligible and must apply within three months of establishing residency (Alberta).

Canadians moving to the U.S. Provincial coverage doesn't continue indefinitely once you leave. Alberta, for example, generally covers absences from Canada of less than six consecutive months, with longer periods available in some cases (Alberta), and Ontario has its own rules for longer absences (Ontario). U.S. health care is expensive, so arrange coverage from your first day. Options include an employer plan or the Affordable Care Act marketplace, which is open to lawfully present immigrants, including people with valid nonimmigrant visas. Medicare is available at 65 to people who qualify through their own or a spouse's work record. Otherwise, a lawfully admitted noncitizen who has lived in the U.S. for at least five years can buy in (SSA).

Snowbirds should carry travel medical insurance for the full length of each stay and confirm how long their province lets them be away.

Life insurance

A policy you already own usually stays in force after you move, unless it excludes foreign residence, but check the terms. Buying a new policy in the country you've left is harder, and many insurers require you to live there when you apply. Beneficiaries in the other country can generally claim, but they may need extra documents, such as Form W-8BEN for a Canadian beneficiary of a U.S. policy. Cash-value policies can also be taxed differently in the two countries, so have one reviewed before you move with it.

Disability insurance

Many disability policies limit or exclude benefits for people living abroad, or require you to return to claim. Read your policy's foreign residence terms before you move. Each country also has a public program tied to your work history:

• Canada Pension Plan disability benefits generally require that you're under 65, have a long-term disability that stops you from working at any job on a regular basis, and contributed in four of the last six years. Credits earned in another country may help you qualify (Government of Canada).
• U.S. Social Security Disability Insurance pays benefits if you've worked long enough and recently enough under Social Security, and the Social Security agreement may help you qualify.

Neither program replaces a high earner's income, so employer group coverage or an individual policy usually has to cover the rest.

Your U.S.–Canada move checklist

• Confirm your residency in each country for the year you move and the year after, including any treaty tie-breaker position and, for snowbirds, your day count and Form 8840.
• Model departure taxes before you leave, including Canada's deemed sale and, if you're giving up citizenship or a long-held green card, the U.S. expatriation tax.
• Plan the timing of asset sales and Roth conversions around your residency date.
• Review every account for its treatment in both countries, especially 401(k)s, IRAs, Roth IRAs, RRSPs, TFSAs, RESPs, FHSAs, 529s, HSAs and Canadian mutual funds.
• File the Roth IRA election with the CRA by the deadline if you're moving to Canada.
• Set up reporting, including the FBAR, Form 8938, Form 8621 for PFICs, Form 3520 and Canada's Forms T1135 and T1161 where needed.
• Plan for real estate, including the Canadian principal residence rules, non-resident withholding on rent and sales, and the foreign buyer ban.
• Choose how you'll convert currency and plan any large transfers.
• Update your estate documents in both countries, and review U.S. estate tax exposure if a Canadian in the family owns U.S. real estate or U.S. stocks.
• Fill insurance gaps in health, life and disability cover before your old coverage ends.

Getting help with a cross-border move

Moving between the U.S. and Canada takes planning well before the move and ongoing coordination afterward. The most expensive mistakes are usually timing mistakes, such as becoming a resident before a sale closes, contributing to the wrong account or missing an election deadline.

Mercer Street provides U.S.-focused financial and tax planning for professionals with international lives. Our deepest cross-border experience is with U.S.–Australia moves, which we cover in the U.S.–Australia cross-border financial planning guide. For a U.S.–Canada move, here's what working with us looks like:

• What we do: U.S. tax planning and consulting, including the U.S. side of the decisions in this guide, financial planning, and analyzing your returns for planning opportunities.
• What we don't do: we don't prepare U.S. or Canadian tax returns, FBARs or Form 8938, and we don't give Canadian tax or legal advice. We can refer you to a qualified preparer, and we work alongside your Canadian accountant, lawyer or financial adviser.
• Investment advice: depending on where you live, licensing rules may limit whether we can give investment advice. If you live in Canada, we can coordinate with a registered adviser there.

If you're planning a move, schedule a consultation.