American Taxpayers Immigrating to Canada: Maximizing the Roth Conversion Strategy


Starting a new chapter in your life by relocating north of the border can be exciting. However, there are many financial and tax implications to take into consideration before you embark on this path. Whether you are an American citizen, a Green Card holder, or otherwise a U.S. resident taxpayer, you may have built up a significant amount of tax deferred investments via IRAs, 401ks, and other types of employer sponsored plans. Once a Canadian tax resident, distributions from most of the plans will be taxable in Canada. In general, the tax rates in Canada for individuals are higher than those in the U.S., and the highest marginal tax brackets are reached at lower levels of income. As such, it is possible that future withdrawals from these U.S. investment vehicles will result in a significantly higher income tax liability than would have been paid had you remained in the U.S. With proper counsel, there is an opportunity to mitigate this situation with some proactive planning.

With the advent of the Tax Increase Prevention and Reconciliation Act, the shackles of income restrictions on Roth conversions were removed. This presents a tax planning opportunity for many Americans, especially those who are considering a move to Canada.

A Roth conversion allows investments held in Traditional/Rollover IRAs, SEPs, and Simple IRAs to convert to a tax-free Roth IRA. The fair market value of the converted amount would be included as ordinary income for the year in which the conversion takes place. Although markets cannot be timed, in theory, the optimal window to convert is when the values of the stocks within the accounts are down, as less tax would be paid on the conversion. The rationale on this strategy includes: diversification of account types to manage future tax liabilities, paying tax at marginal tax rates today in order to avoid paying tax at potentially higher rates in the future, and blessing loved ones with tax free assets as part of your estate plan.

For the American taxpayer planning to relocate to Canada, this presents a golden opportunity. As part of the 5th protocol to the Convention between Canada and the United States (“the Treaty”), Roth IRAs are considered pensions and as such, both the U.S. and Canadian governments recognize the tax-free status of Roth IRAs. This means that if one were to convert a traditional IRA to a Roth IRA prior to moving to Canada, one would completely avoid further taxation on the account basis and any subsequent growth. For many individuals, this minimizes the combined tax liability for the two countries and maximizes what you are able to pass on to your heirs.

To get more granular, let’s view this strategy within a specific context. Let’s say you were approached by your employer regarding an opportunity to transfer from Houston to Calgary. You ponder the move since you always wanted to experience life with the Rockies at your doorstep. You have a 401k in the U.S. that is eligible for rollover to a traditional IRA, with $300,000 currently invested. Since your employer’s offer dictates a move during the spring of the following year, you essentially have two tax years to exploit the Roth conversion opportunity by converting $150,000 prior to the completion of the current tax year, followed by the final $150,000 conversion in the new tax year prior to your spring transition date. This strategy would split the tax liability over two tax years and potentially keep you in a lower tax bracket for each year. Let’s assume that, your federal marginal tax rate is 24% on each conversion ($36,000). Since Texas has no state income tax, as a resident, you would have no state tax your total tax liability to the United States would be 72,000, spread over two tax years, and you would pay nothing to Canada when you take distributions.

Let’s compare this strategy to what would take place if you were to move to Canada and maintain the $300,000 in the 401K. As a resident of Alberta, the 401K would eventually be transferred to a rollover IRA, and you would take distributions later in life. Since the highest tax brackets are reached at much lower income levels in Canada, in this particular example, the distributions from the unconverted 401K, assuming the same income level, would be taxed at around 48% in Alberta (current combined federal/provincial rate). This is double the 24% tax rate of the conversion. Converting the 401K to a Roth IRA prior to becoming a Canadian tax resident would have resulted in effective tax savings of 50% on the $300,000 in question. As well, the growth within the Roth IRA on the original $300,000 would have been free from taxation from either country.

As outlined by the above example, employing a Roth conversion strategy prior to establishing Canadian tax residency could result in substantial tax savings for many individuals. It is important to note that the amount of tax savings that would result from this strategy are highly dependent upon the specific facts and circumstances of each individual as well as future tax and exchange rates. In addition, this strategy is also dependent upon filing the proper Treaty-based election with the filing of your first Canadian resident income tax return. As a result, it is paramount that you seek the guidance of qualified Canada-US Cross-Border financial advisors and tax professionals  prior to making any decision regarding this strategy. Feel free to contact Cardinal Point if you have further questions.

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