Last Updated: April 2026
Canada is one of the most significant countries for tax on departure — the deemed disposition rule means departing Canadians must account for unrealised capital gains on a wide range of assets, creating a potential tax liability on assets that have not actually been sold. Understanding which assets are exempt (Canadian real estate, RRSPs, TFSAs) and which trigger the deemed disposition (worldwide investment portfolios, foreign property, private company shares) is critical for departure planning. For high-net-worth Canadians departing to lower-tax jurisdictions, this can be a multi-million dollar planning exercise.
Canada-to-USA migration (both temporary and permanent) is one of the world's most active bilateral corridors — TN visas, H-1B, and family-based immigration. Key CA-US planning points:
Canada-USA DTA (1980, with 5 protocols through 2007): The Canada-USA DTA is one of the most comprehensive bilateral agreements in the world. Key provisions: CPP/OAS: Article XVIII — Canada withholds 15% on periodic pension; USA taxes all CPP/OAS as income with credit for 15% Canadian withholding. RRSP/RRIF under the DTA: Article XXI — the USA generally defers tax on RRSP/RRIF income until withdrawn (elective deferral under Revenue Procedure 2014-55). Elect this deferral on your first US return after becoming a US resident. TFSA: NOT covered by the DTA — the USA taxes TFSA investment returns currently (PFIC rules may apply to Canadian mutual funds held in TFSA). Canadian deemed disposition and the DTA: the USA generally does not recognise Canada's deemed disposition for US tax purposes — the cost basis of assets carries over at their original acquisition cost in the USA (not the stepped-up FMV used for Canadian departure tax). This creates a future double-tax risk on the same gain. Consult a cross-border US-Canada tax specialist.
RRSP deferral election: File the RRSP deferral election on Form 8891 (now incorporated into Form 8833) on your first US Form 1040 as a US resident. Without this election, the RRSP grows are taxable annually in the USA.
Provincial guides: See individual provincial departure tax guides for Ontario, British Columbia, Alberta, and Quebec — provincial rates significantly affect the total tax on deemed dispositions.
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Get US Expat Tax Help After Leaving Canada →Key exemptions from the deemed disposition under Section 128.1 ITA: (1) Canadian real property (land and buildings): exempt — taxed when actually sold. (2) Canadian business property used in a permanent establishment: exempt. (3) RRSP, RRIF, DPSP, and registered pension plans: fully exempt — RRSP/RRIF balances are not deemed disposed on departure. (4) TFSA: exempt from deemed disposition. (5) Cultural property donated to institutions: exempt. (6) Certain insurance policies and annuities: complex exemption rules apply. What IS caught: worldwide stock portfolios (Canadian and foreign shares, ETFs, mutual funds), foreign real estate, private company shares (Canadian or foreign), partnership interests, options, cryptocurrency, and most capital property. Planning point before departure: consider realising Canadian capital losses to offset the deemed gains. Also consider whether the Section 1244 election (deferral by posting security) is appropriate for illiquid assets. Timing: the deemed disposition occurs on the last day you are a Canadian tax resident — ensuring your residency cessation date is as precise as possible is important. Changing province: if you move from a high-tax province (Quebec, Ontario) to a low-tax province and then depart Canada shortly after, CRA may question the provincial residency — do not artificially change province of residency to manipulate the effective rate.
The departure return (T1 with departure notation) covers: January 1 of the departure year to the departure date — worldwide income for the period of Canadian residency. From the departure date to December 31: only Canadian-source income (reported via Part XIII withholding — no further Canadian return needed for passive income). Filing deadline: April 30 of the following year (June 15 for self-employed, but tax due April 30). The return includes: employment and investment income for the residency period; the deemed disposition gains (reported on Schedule 3 Capital Gains and Form T1243 Deemed Disposition of Property by an Emigrant of Canada); T1161 (list of properties); any provincial income for the period. Potential departure tax instalment: if the departure tax liability (from deemed dispositions) is large, CRA may require an immediate payment on assessment. The Section 220(4.5) deferral (posting security) can defer this payment. Refunds: if you overpaid tax (through employer withholding) for the year, you will receive a refund. Post-departure income: dividends, rental income, pension (after departure): subject to Part XIII withholding — no further filing required unless you elect Section 216 for rental income. File via CRA's NETFILE (while still a Canadian resident you have a NETFILE login) or mail to the appropriate International Tax Services Office.
RRSP on departure to the USA: (1) The RRSP is exempt from Canada's deemed disposition — no Canadian tax event on departure. (2) US recognition: under the Canada-USA DTA Article XXI, the USA recognises the RRSP as a deferred pension plan. To get this US deferral: you must make an election on your first US income tax return (Form 1040) — the election is filed on Form 8833 (Treaty-Based Return Position Disclosure) or as part of your return. If you do NOT make the election: the IRS taxes the inside buildup of the RRSP annually (investment income and gains accumulate as if there is no deferral). (3) RRSP contributions as a US resident: you cannot make new RRSP contributions (you have no Canadian earned income to generate contribution room). (4) RRSP withdrawals as a US resident: Canadian Part XIII withholding of 15% (periodic payments) under the DTA; US taxes the full withdrawal as ordinary income; FTC for the 15% Canadian withholding reduces the US liability. (5) RRSP conversion to RRIF: can occur while non-resident. Annual minimum withdrawals from RRIF must be made; each withdrawal subject to 15% Canadian withholding. (6) Do not collapse the RRSP in a lump sum as a US resident unless you have calculated the total tax — Canadian withholding is 25% for lump sums (reduced to 25% even under DTA for lump sums), and the US taxes the full amount as ordinary income. A cross-border financial planner can model the optimal RRSP/RRIF withdrawal strategy.
Canadian rental property as a non-resident: (1) Part XIII withholding: your Canadian tenant (or their property manager) is legally required to withhold 25% of gross rent and remit to CRA monthly. This is the default. (2) NR6 election: file Form NR6 (Undertaking to File an Income Tax Return by a Non-Resident Receiving Rent from Real Property or Receiving a Timber Royalty) before January 1 of the rental year. If approved, withholding is on net rent (gross rent minus expenses) at 25% — significantly reduces the withholding burden. (3) Section 216 return: file annually by June 30. Elect to be taxed on your actual net rental income at regular Canadian tax rates (which are usually more favourable than 25% of gross). CRA refunds any excess withholding. The Section 216 return is separate from any other Canadian filing. (4) Provincial non-resident tax: Quebec and BC charge non-resident surtaxes on Canadian rental income — factor into analysis. (5) Eventual sale: buyer must withhold 25% of gross sale proceeds (Section 116). File T2062 in advance to reduce the withholding to the actual tax on the gain. The gain is taxed at Canadian rates with the inclusion rate applied. (6) Property management: appoint a Canadian property manager who understands the NR6/Part XIII obligations — they must withhold correctly or become personally liable to CRA.