This is a significant concern for U.S. citizens or green card holders who are also residents of Canada and therefore, must file tax returns in both countries.
An IRA has very similar characteristics to that of a Canadian RRSP – contributions are tax deductible, growth is tax free, and the withdrawals are taxed. However, for Canadian tax purposes, a taxpayer’s contribution to an IRA is not tax deductible. The growth in an IRA will still be tax free and withdrawals will be taxed similarly to how it is taxed in the U.S.
In Canada, individuals will have the option to transfer their lump sum IRA balance to a Canadian RRSP tax free, although U.S. tax will apply on the transfer. A Foreign Tax Credit will alleviate a portion of the resulting double taxation.
Like an IRA is to a Canadian RRSP, similarly a Roth IRA is to a Canadian TFSA. Certain characteristics of a Roth IRA are that the contributions are not tax deductible, but the growth and the withdrawals are tax free. However, although the growth is tax free in the U.S., the Canadian tax authorities considers the account a normal investment account and therefore, will impose tax on the growth of the investments inside the Roth IRA.
The information provided on this page is intended to provide general information. The information does not take into account your personal situation and is not intended to be used without consultation from accounting and financial professionals. Allan Madan and Madan Chartered Accountant will not be held liable for any problems that arise from the usage of the information provided on this page.