CANADIANS Returning from the U.S.
Welcome home, eh?
You spent years—maybe decades—building a career and a life in the United States. You accumulated retirement savings in American accounts. You put down roots.
Now, you’re coming back to Canada. Retirement, family, healthcare, or just missing home —whatever the reason, you’re returning to the country you never stopped calling home.
But you’ve discovered a problem: your U.S. financial advisor can’t help you anymore, and your Canadian advisor doesn’t understand your U.S. accounts.
You’re caught in the middle.
We Bridge the Gap
At Sandhu Wealth, we specialize in helping Canadians who’ve returned from the United States. We’re dually licensed—we can manage your U.S. retirement accounts from Canada right alongside your Canadian accounts.
One advisor. One strategy. Both countries.
What You’re Dealing With
U.S. Retirement Accounts
You’ve got a 401(k), maybe several from different employers. You’ve got an IRA, possibly a Roth IRA. These accounts represent years of savings and tax-advantaged growth.
Can you keep them? Yes. You don’t have to cash out your U.S. retirement accounts when you move to Canada. You don’t have to transfer them to RRSPs (which usually doesn’t make sense anyway).
Can they be managed from Canada? Yes—with the right advisor. Most U.S. institutions won’t serve Canadian residents, and most Canadian advisors aren’t licensed to manage U.S. accounts. We are.
Roth IRA — Critical First-Year Action
If you have a Roth IRA, you must file a treaty election with CRA in the year you become a Canadian resident. This election allows Canada to treat your Roth IRA as tax-free, just as the U.S. does.
Miss this election, and Canada will tax your Roth growth returns.
This is one of the most commonly missed elections in cross-border planning. We make sure it doesn’t get missed.
U.S. Tax Obligations
Depending on your citizenship status, you may still have U.S. tax filing obligations:
U.S. citizens: You file U.S. taxes forever, regardless of where you live.
Former Green Card holders: You may have filing obligations for several years after departure, depending on how you terminated your green card.
Neither: Generally, you won’t have ongoing U.S. filing obligations, but the year of your move requires careful attention.
Social Security and CPP
If you worked in the U.S. long enough, you’re entitled to Social Security benefits. You can collect these while living in Canada.
However, be aware of the Windfall Elimination Provision (WEP)—if you also receive CPP, your Social Security may be reduced. With the cancellation of the Windfall Elimination Provision (WEP), we architect your benefit sequence to ensure you capture the full value of your U.S. and Canadian contributions. We coordinate the timing of your claims to maximize your lifetime income without the historical drag of benefit reductions.
We help you coordinate these benefits for maximum lifetime value.
What We Help With
- Managing U.S. retirement accounts (IRA, 401(k), Roth IRA) from Canada
- Canadian account setup and management
- Providing account data for your accountant to file the Roth IRA treaty election
- Coordination with cross-border tax accountants
- Retirement income planning across both countries
- Social Security and CPP optimization
- Estate planning updates for your return to Canada
The Window Before You Move Back
The period after you’ve decided to return but before you actually become a Canadian tax resident is valuable.
Roth conversions: If you have traditional IRA or 401(k) funds, converting to Roth while still a U.S. tax resident can make sense. You pay U.S. tax on the conversion, then the money grows tax-free forever—in both countries.
Asset repositioning: Restructuring investments for the cross-border reality is easier before the move.
Documentation: Establishing clear records of account values at the time of your return is important for Canadian tax purposes.
We can help you use this window strategically.
Common Mistakes To Avoid
- Cashing out U.S. retirement accounts — The tax hit is almost always worse than keeping the accounts. Don’t do it.
- Missing the Roth IRA election — You get one chance, in your first year as a Canadian resident. Don’t miss it.
- Using an advisor who doesn’t understand cross-border — Your U.S. accounts need someone licensed to manage them from Canada. Your Canadian accounts need someone who understands how they interact with U.S. accounts.
- Ignoring Social Security — You may be entitled to benefits. Understand when to claim for maximum value.
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