Author Topic: Canadian moving to U.S.: deemed dispositions  (Read 9924 times)

Peanut

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Canadian moving to U.S.: deemed dispositions
« on: February 02, 2014, 08:22:04 AM »
I'm considering moving from Canada to the U.S. for a new job opportunity. Right now I'm just trying to collect as much information as possible on the tax implications of such a move.

I currently have about CAD$500k invested in index funds in a taxable account.

I've learned that the Canadian government will require me to pay capital gains tax based on the current value of my taxable investments, as if I had sold them when I emigrated from Canada. Some websites suggest selling the investments before leaving the country. For example:

Quote
Individuals permanently moving to the U.S. should consider disposing of capital property prior to establishing U.S. residence, since unlike Canadian rules, the U.S. will impose a tax on any capital gain based on original cost, from a disposition of capital property by a resident. No provision is made for revaluing the capital property at the time of entry to the U.S., unlike under Canadian capital gains rules.

(from http://www.serbinski.com/taxation-in-usa/moving.shtml)

Other websites point out that you can elect to defer the capital gains tax on deemed dispositions until you actually sell the investments, though.

Has anyone else gone through this before who can recommend the best way of handling this? Should I sell my investments before I move or not?

Thanks!

Self-employed-swami

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Re: Canadian moving to U.S.: deemed dispositions
« Reply #1 on: February 02, 2014, 09:14:19 AM »
Honestly, since you are dealing with a rather sizable account value, I would seek the advice of an experienced accountant or emigration lawyer.
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daverobev

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Re: Canadian moving to U.S.: deemed dispositions
« Reply #2 on: February 02, 2014, 05:19:56 PM »
If you're not going forever, don't worry about it, just keep filing Canadian tax returns - if you're keeping a home, bank accounts, car etc.

If you're going lock, stock and barrel, then yeah, much more complex - but generally you're right, it counts as having sold them on the day you become officially non-resident. 'Tis a bugger. And it is all assets - your primary residence is tax free of course (but if you don't sell it you'll have to *start* paying tax on it as a rental or dispose of it somehow).

Bloody tax people cost a fortune though. I'm pretty sure it is possible to work through it, but yeah, even paying a couple of grand you might well be better off :-/
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Peanut

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Re: Canadian moving to U.S.: deemed dispositions
« Reply #3 on: February 02, 2014, 06:36:36 PM »
If you're going lock, stock and barrel, then yeah, much more complex - but generally you're right, it counts as having sold them on the day you become officially non-resident. 'Tis a bugger.

Yeah, this is the situation I'm referring to. It sounds like I might be better off selling the investments and then re-buying after the move. If I'm going to do that, would it be worth transferring the CAD to USD at the same time and switching to US funds, or does it not matter?

daverobev

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Re: Canadian moving to U.S.: deemed dispositions
« Reply #4 on: February 02, 2014, 07:04:42 PM »
If you're going lock, stock and barrel, then yeah, much more complex - but generally you're right, it counts as having sold them on the day you become officially non-resident. 'Tis a bugger.

Yeah, this is the situation I'm referring to. It sounds like I might be better off selling the investments and then re-buying after the move. If I'm going to do that, would it be worth transferring the CAD to USD at the same time and switching to US funds, or does it not matter?

I think having everything in one country will make your life simpler. I don't know if you'd have to pay tax on investments held in Canada - I think you need to see a lawyer about that - but I'm guessing Canada will probably want to keep their claws in you for half a mil investments. You could wait, claim you're still with significant ties to Canada until you get a better exchange rate, and just sell the things that are close to your purchase price.. and pay the cap. gains as you go.

There's a lot more stuff though - I have no idea what else you have, eg TFSA? If so - the US won't see that as tax-sheltered. RRSP? They will.

Depends, really, on how much gain you've made on those stocks.
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Peanut

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Re: Canadian moving to U.S.: deemed dispositions
« Reply #5 on: February 02, 2014, 07:57:09 PM »
There's a lot more stuff though - I have no idea what else you have, eg TFSA? If so - the US won't see that as tax-sheltered. RRSP? They will.
Yep, I've got both a TFSA and RRSP. I'll have to do more research into how the US views each of these. Good point.

Depends, really, on how much gain you've made on those stocks.
About $16k.

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Re: Canadian moving to U.S.: deemed dispositions
« Reply #6 on: February 03, 2014, 07:05:49 AM »
There's a lot more stuff though - I have no idea what else you have, eg TFSA? If so - the US won't see that as tax-sheltered. RRSP? They will.
Yep, I've got both a TFSA and RRSP. I'll have to do more research into how the US views each of these. Good point.

Depends, really, on how much gain you've made on those stocks.
About $16k.

$16k gain on the $500k? If so - just sell and rebuy - not *ideal* but it'd be like getting an $8k pay rise (cap gains taxed at 50% of income).
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Peanut

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Re: Canadian moving to U.S.: deemed dispositions
« Reply #7 on: February 03, 2014, 07:09:02 AM »
$16k gain on the $500k? If so - just sell and rebuy - not *ideal* but it'd be like getting an $8k pay rise (cap gains taxed at 50% of income).

Fair enough. I'll probably just go that route for simplicity, then. Thanks! :)

Any idea what I should do with the TFSA and RRSP?

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Re: Canadian moving to U.S.: deemed dispositions
« Reply #8 on: February 03, 2014, 09:52:11 AM »
$16k gain on the $500k? If so - just sell and rebuy - not *ideal* but it'd be like getting an $8k pay rise (cap gains taxed at 50% of income).

Fair enough. I'll probably just go that route for simplicity, then. Thanks! :)

Any idea what I should do with the TFSA and RRSP?

The RRSP you can ignore, I believe - you won't be able to add to it, but it will plod along on its own. You'll need to figure out how it works when you come to retire, but the US sees the RRSP as a retirement vehicle so no tax is due or anything.

TFSA I think you'd just have to report dividends as income, as the US doesn't see it as sheltered.

But again - you'd probably want to talk to a cross-border tax specialist to make sure you're right. (Don't get me wrong - in your position, I personally would read up a lot on the internet, try and figure it out myself, do what I understand to be right and cross fingers ;)).
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Peanut

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Re: Canadian moving to U.S.: deemed dispositions
« Reply #9 on: February 03, 2014, 07:50:37 PM »
The RRSP you can ignore, I believe - you won't be able to add to it, but it will plod along on its own. You'll need to figure out how it works when you come to retire, but the US sees the RRSP as a retirement vehicle so no tax is due or anything.

Thanks! I've read that I might need to somehow step up the cost basis of the RRSP before the move because the US calculates cost basis differently than Canada does -- do you know anything about how that works?

TFSA I think you'd just have to report dividends as income, as the US doesn't see it as sheltered.

It sounds like collapsing the TFSA before I leave might make sense if the US doesn't see it as a sheltered account.

But again - you'd probably want to talk to a cross-border tax specialist to make sure you're right. (Don't get me wrong - in your position, I personally would read up a lot on the internet, try and figure it out myself, do what I understand to be right and cross fingers ;)).

Noted. :) I'm trying to figure as much of this out as I can by myself before I turn to a cross-border accountant. I'll probably end up running my final plan by an accountant for a sanity check but I want to go into that discussion as prepared as possible. Thanks for all your help!

daverobev

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Re: Canadian moving to U.S.: deemed dispositions
« Reply #10 on: February 04, 2014, 08:00:12 AM »
The RRSP you can ignore, I believe - you won't be able to add to it, but it will plod along on its own. You'll need to figure out how it works when you come to retire, but the US sees the RRSP as a retirement vehicle so no tax is due or anything.

Thanks! I've read that I might need to somehow step up the cost basis of the RRSP before the move because the US calculates cost basis differently than Canada does -- do you know anything about how that works?

TFSA I think you'd just have to report dividends as income, as the US doesn't see it as sheltered.

It sounds like collapsing the TFSA before I leave might make sense if the US doesn't see it as a sheltered account.

But again - you'd probably want to talk to a cross-border tax specialist to make sure you're right. (Don't get me wrong - in your position, I personally would read up a lot on the internet, try and figure it out myself, do what I understand to be right and cross fingers ;)).

Noted. :) I'm trying to figure as much of this out as I can by myself before I turn to a cross-border accountant. I'll probably end up running my final plan by an accountant for a sanity check but I want to go into that discussion as prepared as possible. Thanks for all your help!

No worries - I know pretty much nothing about the US, the only stuff I know is through reading around, and migrating to Canada from the UK.

Re the RRSP - AFAIK they will just see it as 'a retirement account', they won't care how it came to be. But as I said - I don't actually know anything ;) If you have other ideas, look into them!! Good luck!
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cbgg

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Re: Canadian moving to U.S.: deemed dispositions
« Reply #11 on: February 04, 2014, 06:39:14 PM »
Hi Peanut,

I'm in the middle of moving from Canada to the USA so I've been looking into this as well.  I actually had a phone call with a US Tax Accountant just last week to get some advice.  Maybe we can help each other! 

One thing you should know is that your TFSA is considered a Foreign Trust by the IRS and has no tax advantaged status.  Apparently these turn into a big hassle to manage if you are in the USA so you might as well liquidate before you move.  Actually, they suggest liquidating before you get your visa & become a resident so that you wont have to touch the whole foreign trust thing on your tax return.  The great thing about Canada is that you'll be able to re-fund the account if you move back.

The way I understand it, all of your investments are essentially going to be treated as if you've sold them and re-purchased when you move to the USA, so it might make sense to actually just sell them and move them into a US account so simplify your life.

You can leave your RRSPs where they are.  You'll have to file some extra paperwork each year with your taxes to account for them, but it's not a big deal and the USA does recognize their tax advantaged status. 

You have significant assets to protect.  Spending an hour or two talking to a tax professional who's knowledgeable in this area could be a good idea.



Peanut

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Re: Canadian moving to U.S.: deemed dispositions
« Reply #12 on: February 04, 2014, 06:43:36 PM »
Thanks, cbgg! I'll let you know if I learn anything more as well.

I agree that liquidating the TFSA seems like the obvious choice based on everything I've read so far.

Selling off the non-registered investments also seems to be a reasonable approach. I'm now looking into efficient ways to convert the resulting cash from CAD to USD. It seems like there are two low-cost approaches that people like: (1) using a strategy called Norbert's Gambit, where you buy a stock that's listed on both a Canadian and US exchange and sell on the other exchange, and (2) using a forex trading account with a company like OANDA that offers better exchange rates than banks. I need to spend more time running the numbers to see which of these is the cheaper option.

As for the RRSP, I've heard that most companies won't let you make any changes to your RRSP as a non-resident, but that some, like TD Waterhouse, do let you continue to trade as a non-resident. I'm looking into whether my company's group retirement plan with Manulife gives me the flexibility to move my RRSP to a different company like TDW or not.

daverobev

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Re: Canadian moving to U.S.: deemed dispositions
« Reply #13 on: February 05, 2014, 08:24:18 AM »
Thanks, cbgg! I'll let you know if I learn anything more as well.

I agree that liquidating the TFSA seems like the obvious choice based on everything I've read so far.

Selling off the non-registered investments also seems to be a reasonable approach. I'm now looking into efficient ways to convert the resulting cash from CAD to USD. It seems like there are two low-cost approaches that people like: (1) using a strategy called Norbert's Gambit, where you buy a stock that's listed on both a Canadian and US exchange and sell on the other exchange, and (2) using a forex trading account with a company like OANDA that offers better exchange rates than banks. I need to spend more time running the numbers to see which of these is the cheaper option.

As for the RRSP, I've heard that most companies won't let you make any changes to your RRSP as a non-resident, but that some, like TD Waterhouse, do let you continue to trade as a non-resident. I'm looking into whether my company's group retirement plan with Manulife gives me the flexibility to move my RRSP to a different company like TDW or not.

Questrade is pretty good - you can do N's G with them, DLR.TO to DLR.UN.TO (not that I've done it), and withdraw to a US account. Or maybe you could just keep using them - you can hold US money, pay in US money, etc with them. Might be worth giving them a call. I'd imagine you can continue to trade in the RRSP too.. not sure.

N's G will literally cost you the spread and two trades. It IS the cheapest way. Even the best Forex company (CurrencyFair, which is peer-to-peer.. but just dropped US support, they are more Europe-focussed) will cost you ~0.5%.
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PayTM - pay bills with your credit card. Like Plastiq, but currently a lot of stuff that Plastiq charges for is free. My code is PTM9691063, pay a $50 bill and we both get $10 in PayTM cash which you can use on the next bill. Good for min spend, at least.

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Re: Canadian moving to U.S.: deemed dispositions
« Reply #14 on: February 05, 2014, 10:59:20 AM »
I'm now looking into efficient ways to convert the resulting cash from CAD to USD. It seems like there are two low-cost approaches that people like: (1) using a strategy called Norbert's Gambit, where you buy a stock that's listed on both a Canadian and US exchange and sell on the other exchange, and (2) using a forex trading account with a company like OANDA that offers better exchange rates than banks. I need to spend more time running the numbers to see which of these is the cheaper option.


Oh my goodness, I hadn't even THOUGHT about that!  Crap, I'll need to figure that out as I'll be transferring a few hundred K in cash to the USA as well. 

Peanut

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Re: Canadian moving to U.S.: deemed dispositions
« Reply #15 on: February 05, 2014, 11:19:17 AM »
N's G will literally cost you the spread and two trades. It IS the cheapest way. Even the best Forex company (CurrencyFair, which is peer-to-peer.. but just dropped US support, they are more Europe-focussed) will cost you ~0.5%.
That was the conclusion I reached today after running the numbers as well. Using Norbert's Gambit with RY/RY.TO (better than DLR because the price/share is higher, so you lose less on the bid-ask spread) on Questrade this morning would have saved me about $300 on exchanging $500k CAD->USD compared to the rates that OANDA was quoting.

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Re: Canadian moving to U.S.: deemed dispositions
« Reply #16 on: February 05, 2014, 04:56:46 PM »

Questrade is pretty good - you can do N's G with them, DLR.TO to DLR.UN.TO (not that I've done it), and withdraw to a US account. Or maybe you could just keep using them - you can hold US money, pay in US money, etc with them. Might be worth giving them a call. I'd imagine you can continue to trade in the RRSP too.. not sure.

N's G will literally cost you the spread and two trades. It IS the cheapest way. Even the best Forex company (CurrencyFair, which is peer-to-peer.. but just dropped US support, they are more Europe-focussed) will cost you ~0.5%.

Hi Daverobev,

I'm just learning about this whole Norbert's Gambit thing and am trying to figure out if it's right for me.  I've got a whole bunch of cash that I intend to get invested in a portfolio when I move to the USA.  What I think I'm learning now is that the best move would be to get it invested in a taxable portfolio now (I use Questrade), do the whole N's G thing, then transfer it to my US Vangaurd account...or possibly just keep it in Questrade forever (not my first choice as I'd like to combine it with my husband's assets which are in the USA).

Is that the right idea?  Or am I missing something?

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Re: Canadian moving to U.S.: deemed dispositions
« Reply #17 on: February 05, 2014, 05:39:10 PM »

Questrade is pretty good - you can do N's G with them, DLR.TO to DLR.UN.TO (not that I've done it), and withdraw to a US account. Or maybe you could just keep using them - you can hold US money, pay in US money, etc with them. Might be worth giving them a call. I'd imagine you can continue to trade in the RRSP too.. not sure.

N's G will literally cost you the spread and two trades. It IS the cheapest way. Even the best Forex company (CurrencyFair, which is peer-to-peer.. but just dropped US support, they are more Europe-focussed) will cost you ~0.5%.

Hi Daverobev,

I'm just learning about this whole Norbert's Gambit thing and am trying to figure out if it's right for me.  I've got a whole bunch of cash that I intend to get invested in a portfolio when I move to the USA.  What I think I'm learning now is that the best move would be to get it invested in a taxable portfolio now (I use Questrade), do the whole N's G thing, then transfer it to my US Vangaurd account...or possibly just keep it in Questrade forever (not my first choice as I'd like to combine it with my husband's assets which are in the USA).

Is that the right idea?  Or am I missing something?

If you want to convert the money from CAD to USD then yeah, it is the cheapest way AFAIK. If you invest it now and then sell, withdraw (quit Canada/arrive in US) you'll have to pay any cap gains (or harvest any losses!).

If you don't want to xfer the money from CAD to USD now, but want to hedge, you can buy VUN.TO or something (US index ETF but in CAD). Will the CAD go up or down vs the USD? Who knows. If the money *is to be invested* you might as well invest it now rather than letting inflation eat at it (how long are you talking..?)

I - personally - would look at DLR rather than RY just because RY is a full-on stock, something bad could happen right while you're journaling (that takes ~3 days I believe). I haven't done a N's G myself - only just opening a Questrade unregistered account. But, in theory and in what I've read of others' practise, yes it's the best!

If you're closing or withdrawing from Questrade bear in mind they have a $5k threshold for charging a maintenance fee (sum of all accounts).
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PayTM - pay bills with your credit card. Like Plastiq, but currently a lot of stuff that Plastiq charges for is free. My code is PTM9691063, pay a $50 bill and we both get $10 in PayTM cash which you can use on the next bill. Good for min spend, at least.

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Re: Canadian moving to U.S.: deemed dispositions
« Reply #18 on: February 05, 2014, 06:12:46 PM »

If you want to convert the money from CAD to USD then yeah, it is the cheapest way AFAIK. If you invest it now and then sell, withdraw (quit Canada/arrive in US) you'll have to pay any cap gains (or harvest any losses!).

If you don't want to xfer the money from CAD to USD now, but want to hedge, you can buy VUN.TO or something (US index ETF but in CAD). Will the CAD go up or down vs the USD? Who knows. If the money *is to be invested* you might as well invest it now rather than letting inflation eat at it (how long are you talking..?)

I - personally - would look at DLR rather than RY just because RY is a full-on stock, something bad could happen right while you're journaling (that takes ~3 days I believe). I haven't done a N's G myself - only just opening a Questrade unregistered account. But, in theory and in what I've read of others' practise, yes it's the best!

If you're closing or withdrawing from Questrade bear in mind they have a $5k threshold for charging a maintenance fee (sum of all accounts).

Alright, thanks for the direction.

Regarding closing out Questrade - yeah, I'll have to look into it.  I'll be leaving my RRSP with them while I'm in the USA, so that might help.

Regarding getting invested - I should be in the USA in a matter of months so I'd just planned to leave it in cash for the time being and not have to deal with a bunch of complicated transactions and fees with brokerages.  Looks like this will change that plan since there is a different benefit.

Useful stuff!  I'll have to continue to research and get this all figured out. 
« Last Edit: February 05, 2014, 06:17:18 PM by cbgg »

Peanut

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Re: Canadian moving to U.S.: deemed dispositions
« Reply #19 on: February 06, 2014, 06:05:28 AM »
I - personally - would look at DLR rather than RY just because RY is a full-on stock, something bad could happen right while you're journaling (that takes ~3 days I believe).

I don't think you need to wait the 3 days for journaling in order to complete the trades. You can short RY on the US side a few seconds before you buy RY.TO on the CA side, and then flatten the positions by journaling. This should avoid any exposure to changes in the value of the stock.

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Re: Canadian moving to U.S.: deemed dispositions
« Reply #20 on: February 22, 2014, 10:48:25 PM »
Hello All,

I wanted to follow up and see if anyone here ended up doing Norbert's Gambit, specifically with Questrade. I've used XETrade in the past, been reasonably happy, but I realized I'm taking a loss on the currency conversion. I would love to hear the specifics about a better way, how long it took and how easy it was.
BTW, once you have the USD in your Questrade account, I guess you then do a Wire to your American bank?
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Re: Canadian moving to U.S.: deemed dispositions
« Reply #21 on: February 23, 2014, 09:51:44 AM »

The RRSP you can ignore, I believe - you won't be able to add to it, but it will plod along on its own. You'll need to figure out how it works when you come to retire, but the US sees the RRSP as a retirement vehicle so no tax is due or anything.


This isn't 100% true. Federally, the IRS recognizes the status of an RRSP and so they will let you file a form allowing you to defer the taxes. But not all states recognize them. I lived in California for eight years and they do not recognize them so I had to report the income on my state tax return and pay tax on my earnings. Do check for the state you're planning to move to.

Peanut

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Re: Canadian moving to U.S.: deemed dispositions
« Reply #22 on: February 23, 2014, 09:57:51 AM »

The RRSP you can ignore, I believe - you won't be able to add to it, but it will plod along on its own. You'll need to figure out how it works when you come to retire, but the US sees the RRSP as a retirement vehicle so no tax is due or anything.


This isn't 100% true. Federally, the IRS recognizes the status of an RRSP and so they will let you file a form allowing you to defer the taxes. But not all states recognize them. I lived in California for eight years and they do not recognize them so I had to report the income on my state tax return and pay tax on my earnings. Do check for the state you're planning to move to.

Well, that's annoying. California is indeed the state I'm moving to. Would it still be worth keeping the RRSP open or should I just collapse it before I go?

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Re: Canadian moving to U.S.: deemed dispositions
« Reply #23 on: March 06, 2014, 02:49:29 PM »
Boo, I"m moving to California too. 

Have you heard of the whole issue that you are not supposed to hold index funds or mutual funds in your RRSP if living in the USA?  Wonder how serious that rule is.
 

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Re: Canadian moving to U.S.: deemed dispositions
« Reply #24 on: March 06, 2014, 02:56:20 PM »
Have you heard of the whole issue that you are not supposed to hold index funds or mutual funds in your RRSP if living in the USA?  Wonder how serious that rule is.

Nope, that's news to me. Where did you hear this?

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Re: Canadian moving to U.S.: deemed dispositions
« Reply #25 on: March 06, 2014, 03:17:04 PM »
I heard the thing about maybe not being able to use Mutual funds etc when reading through the comments on this article: http://www.timelessfinance.com/2012/09/11/non-resident-rrsps-canadian-in-america/

Don't know if it's right.  It looks to me like a lot of this stuff is just plain unclear.

Peanut

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Re: Canadian moving to U.S.: deemed dispositions
« Reply #26 on: March 07, 2014, 06:02:03 PM »
My current understanding is that you can continue to hold whatever investments you had before you left, you just can't make trades in your RRSP unless you're working with a company that has agents who are licensed to deal with US residents. I've heard TD Waterhouse is able to do this but that most discount brokerages aren't interested in dealing with you once you leave the country.

cbgg

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Re: Canadian moving to U.S.: deemed dispositions
« Reply #27 on: March 08, 2014, 08:37:56 PM »
My current understanding is that you can continue to hold whatever investments you had before you left, you just can't make trades in your RRSP unless you're working with a company that has agents who are licensed to deal with US residents. I've heard TD Waterhouse is able to do this but that most discount brokerages aren't interested in dealing with you once you leave the country.

Yeah, I keep seeing that too.  It's a bit confusing to me - I've never been asked by my brokerage if I was a US resident and I execute all my own trades, so I don't really understand what the roadblock is to making trades. 

If the rule about not making trades is still relevant the only area is gives me a problem is being able to reinvest cash that is paid out from dividends. 

cbgg

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Re: Canadian moving to U.S.: deemed dispositions
« Reply #28 on: March 11, 2014, 01:07:17 PM »
FYI I asked Questrade and they have no problem with me making trades/purchases within my RRSP account once I'm a non-resident, as long as I do not add any additional contributions (obviously).  I'm delighted to hear this! 

Peanut

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Re: Canadian moving to U.S.: deemed dispositions
« Reply #29 on: March 11, 2014, 07:48:53 PM »
FYI I asked Questrade and they have no problem with me making trades/purchases within my RRSP account once I'm a non-resident, as long as I do not add any additional contributions (obviously).  I'm delighted to hear this!

Did you specifically mention to them that you're moving to the US, not just that you're leaving Canada? When I asked Questrade they said they can deal with non-residents of Canada, but that they can't (or won't) deal with US residents.

cbgg

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Re: Canadian moving to U.S.: deemed dispositions
« Reply #30 on: March 11, 2014, 09:54:46 PM »
I did tell them that I was moving to the USA...but maybe I should ask again and see if I get the same answer. Ugh, that's disappointing to hear.

It seemed to be relevant that I was talking about an RRSP. Did you ask in reference to an RRSP?

Peanut

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Re: Canadian moving to U.S.: deemed dispositions
« Reply #31 on: March 12, 2014, 09:00:00 AM »
I did tell them that I was moving to the USA...but maybe I should ask again and see if I get the same answer. Ugh, that's disappointing to hear.

It seemed to be relevant that I was talking about an RRSP. Did you ask in reference to an RRSP?

Yes, I asked about RRSPs specifically. It sounds like we're getting conflicting answers here. That's annoying!

CanuckExpat

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Re: Canadian moving to U.S.: deemed dispositions
« Reply #32 on: March 12, 2014, 01:19:57 PM »
Yes, I asked about RRSPs specifically. It sounds like we're getting conflicting answers here. That's annoying!

If your wondering, it's because these aren't specifically Canadian laws (or really even American) preventing them from doing business with you, it is just that in response to some recent changed in American laws regarding foreign banks, a lot are finding it easier not to do business with US residents: http://www.ibtimes.com/americans-abroad-cant-bank-smoothly-fatca-tax-evasion-reform-comes-play-1517032
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