A Comparison of Account Types in Canada and the US - MCA Cross Border Advisors Inc. (2024)

In this day and age of 24/7 integrated and electronic global markets, capital is generally mobile and easily flows around the world as investors seek higher investment returns. Of course, human constructs such as political borders, capital controls, national regulations, and differences in account characteristics can affect such flows between countries.

An earlier blog entry, found here, addressed some of the regulatory issues associated with portfolio management between Canada and the US. This blog entry outlines the various account types in Canada and the US and how they correspond or transition to a similar account type in the other country, thereby providing additional guidance for clients looking to move between Canada and the US.

Note, however, that each client’s specific situation will likely involve more complex considerations than simply moving capital across borders, so this entry outlining account transition possibilities is solely intended for educational purposes only.

Canadian Residents Looking to Move to the US

Taxable/Non-Registered to Taxable/Non-Qualified Accounts

Assets in Canadian non-registered accounts can be transitioned to US non-registered accounts. While there won’t be a change to the taxable nature of the assets. There may be changes in the adjusted cost base (ACB) with a move between borders.

Investors holding Canadian mutual funds, ETFs, and Real Estate Income Trusts (REITs) should be aware that these investments are typically classified as Passive Foreign Investment Companies (PFICs) by the IRS, with extremely punitive tax consequences for US tax filers. Typically, these assets should be liquidated prior to moving to the US.

RRSP/RIF/LIRA/LIF Accounts

These retirement accounts are creations of the Canadian government and subject to the Canadian tax regime; the US analogue is an Individual Retirement Account (IRA). While the US government recognizes the tax-deferred nature of assets within Canadian retirement accounts, such assets cannot be transferred to US IRAs. Most clients leave their Canadian retirement assets in Canada.

PFICs are not an issue within Canadian retirement accounts, so investors can continue to hold Canadian mutual funds, ETFs, and REITs within their RSP and RIF accounts.

Registered Education Savings Plan (RESP) Accounts

These savings accounts for college and university are creations of the Canadian government and subject to the Canadian tax regime; the US analogue is a 529 account.

The US government unfortunately does not recognize the tax-deferred nature of assets within Canadian education savings accounts, and taxes US persons on any earnings within a RESP annually. In addition, the RESP may be treated as a foreign trust for US tax purposes, resulting in extra costs, complications, and filings.

With RESPs, there are additional tax complications that need to be considered based on the specific client situation and discussing these complications is outside the scope of this blog entry.

Tax-Free Savings Accounts

The TSFA is another creation of the Canadian government that is subject to the Canadian tax regime. The closest US analogue to the TFSA is the Roth IRA. TFSA assets, however, cannot be transitioned to Roth accounts; rather, the assets need to be liquidated prior to moving south of the border. They can then be combined with one’s taxable/non-registered assets.

US Residents Looking to Move to Canada

Taxable/Non-Qualified to Taxable/Non-Registered Accounts

Assets in US non-registered/non-qualified accounts can be transitioned to Canadian non-registered accounts. There may be changes in the adjusted cost base (ACB) with a move between borders; however, there won’t be a change to the taxable nature of the assets.

Investors holding US mutual funds should be aware that these investments are meant only for US residents, so these assets should be sold to cash prior to moving to Canada

Investors holding US municipal bonds should be aware that there is no further tax advantage to doing so once they have exited the US. MCA generally recommends liquidating this component of the portfolio upon a client’s exit.

IRA Accounts

While it is possible to (indirectly) transfer assets from a US IRA to a Canadian RSP account, there are additional tax complications that need to be considered based on the specific client situation and discussing these complications is outside the scope of this blog entry. Note, though, that in general (and in practice) it is typically easier to leave the IRA assets in the US to be managed by (a) properly licensed investment firm(s).

Roth Accounts

Assets in a Roth account cannot be transitioned to Canadian TFSAs. Luckily, under the Canada/US Tax Treaty, the tax-free status of the Roth account can be maintained if there are no further contributions to the account after moving to Canada. A one-time election needs to be made with the Canada Revenue Agency on the tax return for the year of the move in order to maintain this tax-free status.

401K/403B Accounts

In general, these assets can be rolled over on a tax-free basis to an individual IRA account. As indicated above, it is typically easier to leave these assets in the US.

529 Accounts

A Qualified Tuition Program or 529 plan is a tax-advantaged savings plan in the US sponsored by states, state agencies, or educational institutions; the Canadian analogue is the RESP.

The Canadian government unfortunately does not recognize the tax-deferred nature of assets within 529 plans. When the contributor to the plan is a Canadian resident, the plan is potentially considered a deemed resident trust for Canadian tax purposes, with annual income for the plan taxable in Canada. It is typically more optimal for contributions to the 529 plan be made by US residents.

MCA Cross Border Advisors Inc. has extensive experience and expertise in transitioning accounts and portfolios between Canada and the US. With expertise in portfolio construction, manager search and selection, tax strategy, and financial planning, our team of experts can help create and structure a Canada/US cross-border optimized portfolio that remains aligned with your investment objectives and risk tolerance.

A Comparison of Account Types in Canada and the US - MCA Cross Border Advisors Inc. (2024)

FAQs

What are the different types of Canadian investing accounts? ›

Types of investments
  • Annuity. An annuity is a type of investment contract that pays you income at regular intervals, usually after retirement.
  • Bond. ...
  • Canada Savings Bond ( CSB ) ...
  • Exchange traded fund ( ETF ) ...
  • Guaranteed investment certificate ( GIC ) ...
  • Mutual fund. ...
  • Security. ...
  • Segregated fund.
Aug 5, 2022

What is the Canadian equivalent of a Roth IRA? ›

The Canadian equivalent of a Roth IRA is a TFSA. Although the plans have differences, there are significant similarities. A Roth IRA and a TFSA are funded with after-tax dollars, and the growth and income earned in the account can be free from taxation if the rules are followed.

What is the US equivalent of a TFSA account? ›

Canada's Tax-Free Savings Account (TFSA) is fairly similar to the United States' Roth IRAs. Both of these retirement-focused vehicles are funded with after-tax money (there's no deduction for the contribution), but they do grow tax-free, and withdrawals are not taxed.

What's the difference between a TFSA and RRSP? ›

TFSA lets you shelter tax on investment returns, while RRSP allows you to defer tax until withdrawal later on. Both of these accounts have their pros and cons, and whether you choose an RRSP, a TFSA — or in many cases both — depends on your needs and circ*mstances.

What are different types of mutual funds in Canada? ›

Below is a description of some of the different types of mutual funds available in today's Canadian marketplace:
  • Money Market Mutual Funds. ...
  • Fixed Income Mutual Funds. ...
  • Dividend Mutual Funds. ...
  • Growth/Equity Mutual Funds. ...
  • Balanced Mutual Funds. ...
  • Index Funds. ...
  • Closed End Mutual Funds.

What is Canada's equivalent of FDIC? ›

Canada Deposit Insurance Corporation (CDIC) is a federal Crown corporation that protects more than $1 trillion in Canadian deposits.

What is the Canadian equivalent to a Roth 401k? ›

Key Takeaways. Registered Retirement Savings Plans (RRSPs) are essentially the Canadian equivalent of the American 401(k), and vice versa. RRSPs and 401(k)s are both retirement savings accounts, and each has similar tax benefits.

What is a Roth account in Canada? ›

A ROTH IRA allows an individual to direct after-tax income to an investment account up to a specified amount each year. Both the earnings on the account and withdrawals after the age of 59.5 are tax free in the US and Canada due to the tax treaty.

Does Canada tax Roth IRA distributions? ›

Furthermore, income accruing in your Roth IRA is generally subject to Canadian tax unless you make a one-time election under the Canada- U.S. Income Tax Treaty (Treaty) to defer taxation. When distributions are eventually made, they too may be exempt from Canadian tax by the Treaty (under certain conditions).

Can a US citizen living in Canada have a TFSA? ›

U.S. citizens who reside in Canada may establish registered accounts such as a RRSP, RESP or TFSA. However, the Canadian tax benefits arising from these registered accounts may potentially be offset by U.S. compliance obligations and/or applicable U.S. taxes.

Should US citizens in Canada have TFSA? ›

A U.S. citizen wanting to invest through a TFSA should consult with their tax advisor to ensure the tax benefits will outweigh the costs (both tax and accounting). Investment income, both inside and outside a TFSA, should be managed to ensure there is no residual U.S. tax liability.

What is a TFSA in Canada? ›

What is a TFSA. The TFSA program began in 2009. It is a way for individuals who are 18 years of age or older and who have a valid social insurance number (SIN) to set money aside tax-free throughout their lifetime. Contributions to a TFSA are not deductible for income tax purposes.

What is the difference between a TFSA and a GIC? ›

A GIC is an investment that pays a modest, fixed interest rate, while a TFSA is an account that can hold multiple investments. A GIC might pay a higher interest rate than a TFSA, but a TFSA can hold assets like stocks and real estate, which can appreciate quickly depending on the state of the economy.

How do GICs work in Canada? ›

Guaranteed Investment Certificates (GICs) and term deposits are secured investments. This means that you get back the amount you invest at the end of your term. The key difference between a GIC and a term deposit is the length of the term.

How does RRSP work in Canada? ›

When you contribute money to a RRSP, your funds are "tax-advantaged", meaning that they're exempt from being taxed in the year you make the contribution. Any investment income earned from investments held within the RRSP can then grow tax-deferred, as long as the money remains within the RRSP, until it's withdrawn.

What are the disadvantages of mutual funds in Canada? ›

Mutual Funds: An Overview

Some of the advantages of this kind of investment include advanced portfolio management, dividend reinvestment, risk reduction, convenience, and fair pricing. Disadvantages include high expense ratios and sales charges, management abuses, tax inefficiency, and poor trade execution.

Which mutual fund is best in Canada? ›

What are the best mutual funds in Canada?
  • CI Canadian Dividend Fund Series F.
  • Mackenzie Bluewater Canadian Balance Fund Series F.
  • AGF Global Select Series F.
  • Blue Bay Emerging Markets Corporate Bond Fund.
  • Mawer Global Equity Fund.
  • RBC Life Science and Technology Fund Series F.
  • TD U.S. Mid-Cap Growth Fund Class F.
Jun 1, 2023

What are the 4 types of investments? ›

Different Types of Investments
  • Mutual fund Investment. ...
  • Stocks. ...
  • Bonds. ...
  • Exchange Traded Funds (ETFs) ...
  • Fixed deposits. ...
  • Retirement planning. ...
  • Cash and cash equivalents. ...
  • Real estate Investment.

What is the difference between the banking system in Canada and the United States? ›

In the U.S., banking is regulated at both the federal and state level. In Canada, banking is regulated at the federal and provincial level. Both scenarios have resulted in a patchwork of standards. And in Canada, provinces like Quebec guard their jurisdictions carefully.

What is the equivalent of GIC in USA? ›

If you're trying to compare GICs to a U.S. equivalent, they're similar to both certificates of deposit (CDs) and bonds. With CDs, you're agreeing to save money with your bank or credit union for a certain period of time. Once the CD matures, you can withdraw the money you deposited and the interest earned.

Are Canadian banks safer than US banks? ›

Canadian banks are well insured

When you deposit your money in a Canadian bank, you can rest assured that it'll be there when you go to take it out. That's because the Canada Deposit Insurance Corporation (CDIC) will insure up to $100,000 per account, per institution.

What is the Canadian equivalent to a 401k? ›

What is the equivalent of a 401(k) in Canada? The Registered Retirement Savings Plan is a tax-deferred retirement plan that is analogous to the traditional IRA in the United States. Each year, individual Canadians can contribute funds to their RRSP account up to a maximum limit.

Does Canada honor Roth IRA? ›

Canadian tax residents cannot transfer a Roth IRA to a Registered Retirement Savings Plan (RRSP) or a Tax Free Saving Account (TFSA). Instead, the Canada-US Tax Treaty allows Canadian tax residents to file a one-time irrevocable election for each Roth IRA that they own.

Is Roth 401k taxed in Canada? ›

Because only traditional IRAs and 401(k) plans are referred to in these provisions, these plans continue to enjoy the tax-deferral treatment in Canada. By contrast, the accrued income in either a Roth IRA or a Roth 401(k) plan will be taxable in Canada each year.

What happens to my Roth IRA if I leave the country? ›

Nothing happens to your Roth IRA if you move abroad. The funds will still grow tax-free, and all the same required minimum distribution rules apply once you reach retirement age. The only thing that could change when you move abroad is your ability to contribute more money to a Roth IRA.

What is the best retirement plan in Canada? ›

The best kinds of pension plans in Canada are the Defined Contribution Pension Plan (DCPP), Registered Retirement Savings Plan (RRSP), Tax-Free Savings Account (TFSA), Canada Pension Plan (CPP), Old Age Security (OAS), and Guaranteed Income Supplement (GIS).

Does Canada tax US retirement income? ›

Article XVIII (5) Social Security

(a) a benefit under the social security legislation in the United States paid to a resident of Canada shall be taxable in Canada as though it were a benefit under the Canada Pension Plan, except that 15 per cent of the amount of the benefit shall be exempt from Canadian tax; and.

Are distributions from a Roth IRA always tax free? ›

If you haven't met the five-year holding requirement, your earnings will be subject to taxes but not penalties. Withdrawals from a Roth IRA you've had more than five years. If you've met the five-year holding requirement, you can withdraw money from a Roth IRA with no taxes or penalties.

Are all distributions from a Roth IRA tax free? ›

A Roth IRA is an IRA that, except as explained below, is subject to the rules that apply to a traditional IRA. You cannot deduct contributions to a Roth IRA. If you satisfy the requirements, qualified distributions are tax-free. You can make contributions to your Roth IRA after you reach age 70 ½.

Is a Roth IRA exempt from taxes? ›

Roth IRAs. A Roth IRA differs from a traditional IRA in several ways. Contributions to a Roth IRA aren't deductible (and you don't report the contributions on your tax return), but qualified distributions or distributions that are a return of contributions aren't subject to tax.

How long can I live in Canada as a U.S. citizen? ›

Most visitors can stay for up to 6 months in Canada. If you're allowed to enter Canada, the border services officer may allow you to stay for less or more than 6 months.

Can I be a dual citizen of the US and Canada? ›

Yes, the U.S. allows dual citizenship by default. The government does not require naturalized U.S. citizens to give up their citizenship in their country of origin.

Can U.S. citizens hold Canadian mutual funds? ›

The U.S. government considers most Canadian-domiciled mutual funds and ETFs to be Passive Foreign Investment Companies (PFICs). As a U.S. citizen, you must make special filings to report these holdings to the IRS. These can be complicated, and paying a tax expert to do it can be expensive.

Do dual citizens have to pay taxes in both countries? ›

Being a dual citizen means that a person is considered a citizen/national of two countries at the same time, and is subject to both country's tax laws. Something to remember is that each country has its own laws dictating who qualifies as a citizen.

Can I live in Canada as a U.S. citizen? ›

3) Can I live in Canada as an American citizen? Yes, if you are an American citizen, you may live in Canada. If your stay exceeds 180 days, you will most likely need a visa. You will also need a visa or work permit if you intend to work in Canada.

Do US citizens pay capital gains tax in Canada? ›

As a U.S person living in Canada, you are taxed on money earned in Canada. This can be from investment interest or capital gains, employment income, or if you take money out of your IRA or 401(k).

How do I avoid tax on my savings account in Canada? ›

How to save on taxes in Canada by opening a TFSA. You can avoid paying tax on a savings account in Canada by opening a tax-free savings account, or TFSA in 2023. Canadian residents who are 18 or older and have a valid Social Insurance Number (SIN) are eligible to open a TFSA.

What is the best TFSA account in Canada? ›

Top high-interest TFSA rates in Canada:
Savings AccountInterest RateMonthly Fee
Peoples Trust Tax-Free Savings3.00%$0
Steinbach Credit Union TFSA Variable Savings3.75%$0
Tangerine Tax-Free Savings Accountup to 5.00%$0
VersaBank Sunrise TFSA Daily Interest Savings Account1.05%$0
22 more rows
May 31, 2023

How much money can you have in a TFSA Canada? ›

Investment income earned by, and changes in the value of your TFSA investments will not affect your TFSA contribution room for current or future years. The annual TFSA dollar limit for the year 2023 is $6,500. The annual TFSA dollar limit for the years 2019 to 2022 was $6,000.

Which bank has the best TFSA interest rate? ›

The best TFSA for 2023 belongs to EQ Bank which had one of the highest standard interest rates for 2022 amongst its competitors. This pick helps you grow your money tax-free even faster. This account comes with: CDIC insured.

Which is better GIC or RRSP? ›

RRSPs allow your money to grow tax-deferred, which means you can earn more interest over time. GICs are relatively safe because they're guaranteed, which means you won't lose any of your original investment. Contributing to an RRSP can lower the amount of income tax you pay while you're still working.

Which is better GIC or mutual funds? ›

How to Choose: If you're looking for a safe investment with a guaranteed return, GICs are a good option. But if you're willing to take on more risk in exchange for the potential for higher returns, mutual funds may be a better choice.

What is a disadvantage of a GIC? ›

Disadvantages of GICs

Not all investment returns are taxed equally, and unlike capital gains and dividends, interest income earned from GICs is fully taxable in the year received. GICs typically offer very low returns, especially after accounting for taxes and inflation, which can erode your purchasing power.

Do GICs exist in the US? ›

In the United States, GICs are created and promoted by insurance companies and have a slightly different client focus.

Do you have to pay taxes on a GIC in Canada? ›

If you hold a GIC in an RRSP account, your GIC is tax deductible in Canada, plus any interest earned grows tax free. However, if you cash out the GIC in your RRSP account, you will pay tax on it.

What happens to RRSP if you leave Canada? ›

Contrary to popular belief, you are not required to deregister your RRSP/RRIF upon ceasing Canadian residency. You have the option to keep your RRSP/RRIF intact and have the income continue to grow tax-deferred for Canadian tax purposes.

What is the best way to use RRSP in Canada? ›

RRSP benefits are strongest when you use the funds as retirement income by converting your RRSP to a Registered Retirement Income Fund (RRIF) or an annuity. You must convert by the end of the calendar year in which you turn 71, but you can do it sooner if you retire earlier.

Is RRSP tax free in Canada? ›

Any income you earn in the RRSP is usually exempt from tax as long as the funds remain in the plan; you generally have to pay tax when you receive payments from the plan.

What is the difference between a TFSA and other types of investment? ›

The major difference between RRSP and TFSA accounts centres around tax implications. RRSPs offer a tax deduction when you contribute, but you have to pay tax when you withdraw the money. TFSAs offer no up-front tax break, but you don't pay tax on any withdrawals, including growth.

What are the different types of TFSA in Canada? ›

There are three types of TFSAs that can be offered: a deposit, an annuity contract, and an arrangement in trust. Banks, insurance companies, credit unions, and trust companies can all issue TFSAs. For more information about a certain type of TFSA , contact a TFSA issuer.

What are the 3 types of investment accounts? ›

Three of the Most Common Investment Account Types
  • General Investing Accounts. A general investing account offers access to a wide range of potential investment choices, including stocks and bonds. ...
  • Retirement Accounts. ...
  • Education Savings Accounts.

How is a GIC different from other investments? ›

A GIC is a single investment that pays a fixed or variable rate of interest over a predetermined amount of time. A mutual fund allows investors to invest in multiple asset classes, including stocks and bonds, but it does not guarantee a minimum return or impose any time constraints on the capital invested.

What are the 3 types of TFSA? ›

How to Open a TFSA
  • Look for financial institutions that offer TFSAs (types include deposit, annuity, trust arrangement, and self-directed TFSA).
  • Apply for an account. ...
  • Once your account is approved and open, the financial institution will register the account as a qualifying arrangement with the Canadian Revenue Agency.

Are mutual funds and TFSA the same? ›

The only difference between buying mutual funds in an RRSP or a TFSA is that the money in your TFSA can be withdrawn tax-free. This is because TFSA contributions are made using after-tax dollars, whereas RRSP contributions are tax-sheltered by the government (up to a certain point, of course!).

Can you hold US dollars in a TFSA? ›

You can contribute foreign funds to a TFSA. However, your issuer will convert the funds to Canadian dollars (using the exchange rate on the date of the transaction), when reporting this information to us. The total amount of your contribution, in Canadian dollars, cannot be more than your TFSA contribution room.

Is TFSA only in Canada? ›

TFSAs are available to every Canadian resident, who is 18 years of age or older with a valid Social Insurance Number (SIN). To open a TFSA with TD, you must be of the age of majority in your province of residence.

What is the difference between a tax-free GIC and a TFSA? ›

A GIC is an investment that pays a modest, fixed interest rate, while a TFSA is an account that can hold multiple investments. A GIC might pay a higher interest rate than a TFSA, but a TFSA can hold assets like stocks and real estate, which can appreciate quickly depending on the state of the economy.

Is TFSA good in Canada? ›

The TFSA is one of the safest options for saving money for both short and long-term financial plans. They have non-tax-deductible features which make the amount in your TFSA safe and secure from taxation. The TFSA is one of the best options for all Canadians to make for a safe and secure way to save.

What are the different types of investment accounts in the US? ›

U.S. investors seeking to accomplish financial goals by investing in securities generally have access to four types of investment accounts—brokerage accounts, Individual Retirement Accounts (IRAs), education accounts, and employer-sponsored retirement plans.

What are the 5 classes of investment? ›

Asset classes are groups of similar investments. The five main asset classes are cash and cash equivalents, fixed-income securities, stocks and equities, funds, and alt investments.

What are the negatives of GIC? ›

Disadvantages of GICs

Not all investment returns are taxed equally, and unlike capital gains and dividends, interest income earned from GICs is fully taxable in the year received. GICs typically offer very low returns, especially after accounting for taxes and inflation, which can erode your purchasing power.

What is the main disadvantage of GIC? ›

Disadvantages. The main disadvantage of glass ionomer sealants or cements has been inadequate retention or simply lack of strength, toughness, and limited wear resistance. For instance, due to its poor retention rate, periodic recalls are necessary, even after 6 months, to eventually replace the lost sealant.

Why not to buy a GIC? ›

The biggest risk you may face with GICs is the potential for capital erosion, or the potential for your GIC's interest rate to lag behind the current rate of inflation. For example – let's say you invested $10,000 in a 1-year GIC, with an interest rate of 2%, but the inflation rate was 3% over the same term.

Top Articles
Latest Posts
Article information

Author: Foster Heidenreich CPA

Last Updated:

Views: 6567

Rating: 4.6 / 5 (76 voted)

Reviews: 91% of readers found this page helpful

Author information

Name: Foster Heidenreich CPA

Birthday: 1995-01-14

Address: 55021 Usha Garden, North Larisa, DE 19209

Phone: +6812240846623

Job: Corporate Healthcare Strategist

Hobby: Singing, Listening to music, Rafting, LARPing, Gardening, Quilting, Rappelling

Introduction: My name is Foster Heidenreich CPA, I am a delightful, quaint, glorious, quaint, faithful, enchanting, fine person who loves writing and wants to share my knowledge and understanding with you.