How to Move a Taxable Account from the US to Canada

In my experience, it is hard to find a US brokerage that will hold a taxable (called “non-registered” here in Canada) account for a Canadian resident. So when you move, you’ll likely by moving your US taxable investments to Canada with you. The good news is that it’s easy to find a Canadian brokerage that will hold this for a US citizen, and provide you with the tax documents that you need to do both your Canadian and US taxes.

This article will just cover how to move US taxable investments to Canada. Moving retirement accounts (e.g. an IRA to an RRSP) is significantly more complicated and needs to be done very carefully. I’ll cover that in a future post.

Step 1: Track the Adjusted Cost Base for your Holdings

This warrants its own post, but it’s important to track the adjusted cost base (ACB) of your non-registered investments from both the US and Canadian perspective. For the US side, the ACB is based on the price you paid when you bought the assets. On the Canadian side, though, the ACB is set to the value of your assets on the day you move to Canada, and then continues to adjust as additional sales or purchases are made.

Note that this is the day you move to Canada, not the day your account moves to Canada, thus you’ll almost certainly need to track it yourself, rather than relying on your Canadian brokerage.

A popular tool for tracking this is the aptly named adjustedcostbase.ca. If you use this, I strongly encourage you to backup your data whenever you make updates, just in case.

Step 2: Prepare your US Holdings for Transfer

If you hold individual stocks or ETFs already, you should be OK. It wouldn’t hurt to check with the Canadian brokerage you’re going to use (see step 3), but unless you’re holding something unusual it shouldn’t be an issue.

If you hold mutual funds, you’ll want to convert them to their ETF equivalents, if possible. The reason for this is that you likely won’t be able to hold US mutual funds in your Canadian brokerage account. So if you’re invested in something like VTSAX, you’ll want to contact Vanguard and ask them to convert it to the equivalent amount of the ETF version — VTI. This won’t be a taxable event.

If you hold mutual funds that don’t have ETF equivalents, your options are limited. You could check with your Canadian brokerage about holding the mutual fund, but the answer will likely be no. In that case, your best option may be to sell the fund and buy a similar ETF, but this will be a taxable event.

And just to be clear, even though US mutual funds are typically off-limits for Canadian residents, the same rules don’t generally apply to US ETFs. In fact, because they have lower fees, US ETFs are popular among savvy Canadian investors without any particular ties to the US.

Step 3: Open a Canadian Brokerage Account

I discuss this in more detail elsewhere but, in brief, my recommendation is usually Wealthsimple or Questrade. Both of these brokerages periodically offer a sign-up bonus (e.g. some % of cashback on the incoming assets) so it’s worth checking both when the time comes to transfer your account.

When you create your account, you’re going to set up a non-registered (meaning taxable) USD account. By keeping the account in USD, you’ll both have a place to transfer your US holdings into and make it easier to avoid inadvertently buying something (e.g. a Canadian ETF) with PFIC filing requirements. This does open the door to potential currency risk but, in my opinion, the advantages outweigh the risks in terms of transferring in a US taxable account.

You likely won’t be able to make your Canadian brokerage account until you have a Canadian address, but that’s OK. You shouldn’t have any trouble initiating the transfer after you move, so long as you do not preemptively update the address on your US brokerage to something Canadian. If you do this, the brokerage could potentially freeze the account or force a quick liquidation. Thus, rather than updating the address on your US account, my advice would be to simply set up a Canadian brokerage once you have an address, and then initiate the transfer from your US account. Once the transfer goes through, you can download your historical statements and close the US account.

Note: if you were looking to set up a non-registered brokerage account in Canada from scratch (meaning you weren’t transferring in US assets) I might recommend a different approach. For example, you could potentially set up a CAD account and invest in individual stocks to avoid PFIC requirements, depending on your goals and other asset allocation.

Step 4: Initiate an In-Kind Transfer

This is where we actually move our US taxable investments to Canada. The exact process will depend on the brokerage, but the key is to do an in-kind transfer. That means your US brokerage will transfer the holdings to your Canadian brokerage, as opposed to selling them and sending the cash. If you do it as an in-kind transfer, it is not a taxable event. If you liquidate your US holdings and send the cash, it’s taxable.

Here are the steps for Questrade.

Here are the steps for Wealthsimple.

After you initiate the transfer, it takes a while (around 20 business days). Because it’s an in-kind transfer, though, you aren’t out of the market during this time.

Final Thoughts

That’s it! Moving taxable investments from the US to Canada is quite easy (although a bit slow). And if you’re already invested in ETFs (or mutual funds with ETF equivalents), you should be able to do it in a way that doesn’t trigger any taxable events. If you have any questions, though, please don’t hesitate to post them in the comments.

Two other things I want to mention:

1) Exit Tax — Canada charges an exit tax when people who were Canadian tax residents move away. For your taxable account, this tax would be on the gains since you moved to Canada. In other words, Canada treats your taxable account as if you bought it the day you moved to Canada and sold it the day you moved away.

2) Estate Planning — This is definitely outside the scope of this post, but as you transfer your assets from the US to Canada, you’ll need some sort of Canadian estate plan to cover these assets. A quick and dirty option if you want to keep your US estate plan intact and add a separate will for your Canadian assets could be something like MyExpatWill from LegalWills. This undoubtedly wouldn’t work for all situations, but it may be a good solution for some.

Comments

6 responses to “How to Move a Taxable Account from the US to Canada”

  1. Ian Jamison Avatar
    Ian Jamison

    Thank you so much for these posts – moving from the US to Canada and they are a godsend.

    One question – are you sure that you can move US Mutual Funds into equivalent ETFs without triggering a taxable event? I have a taxable investment account at Fidelity, holding a Total Market Mutual Fund (with LTCGs).

    I called and asked if there was an equivalent ETF I could move this to without triggering taxes and they told me that was only possible for some retirement accounts, not taxable ones.

    Which seems to conflict what I read in your post here. Did I just catch the wrong person? It was specifically that this strategy wasn’t possible in a taxable account. *Not* that there wasn’t a matching ETF or anything…

    Thank you so much for your time and expertise!

    1. Hi Ian, as long as there is an identical ETF version, they should be able to journal it over. If the mutual fund you’re talking about is FSKAX, though, it doesn’t look like there’s a direct ETF equivalent from Fidelity. Thus, I assume the agent you spoke to just meant that you could sell it and buy a similar ETF (as opposed to an identical one) if you were in a retirement account. It couldn’t hurt to talk to another agent but, unfortunately, I’m not sure that you’ll be able to convert this particular mutual fund to an ETF.

      1. Ian Jamison Avatar
        Ian Jamison

        Got it, that’s probably what happened. It was actually FZROX, which is Fidelity proprietary.

        One piece of feedback that might be relevant to your writings is that in further discussions with Fidelity they *will* continue holding that FZROX mutual fund position even once I’ve moved to Canada. So for people in similar pickles, Fidelity might be a good option to either retain or in-kind transfer to if you have an otherwise immoveable mutual fund with unrealized LTCGs. Thanks again for sharing so much info about this!

        1. Interesting, that’s good to know. So, just to make sure I understand, Fidelity will let you keep an existing position after you moved to Canada, but they wouldn’t let you buy additional shares, is that right? What about automatic re-investment? Thanks!

  2. Catherine Avatar

    I am a Canadian. i worked in the USA for 16 years and moved back to Canada in 2012. I have left all my accounts – 401K, Roth IRA, and brokerage – at Fidelity.
    I have a large 401k approx $2mill. Is it better, to move it to canada in lump sums, rollover the whole thing, or leave it at Fidelity in USA as a pension and just set up recurring withdrawls (monthly/quarterly).
    There is a 72rule that can be applied between ages 55-59.5 to cancel the 10% early withdrawl fee.

    thank you

    1. Hi Catherine — My situation is a bit different than yours (as I’m a dual citizen) so much of what is on this website may not apply to you. Also, with that size of an account, I’d strongly encourage you to talk to a cross-border planner and / or CPA to make sure you’re handling it correctly.

      With those caveats in mind, I would avoid moving it as a lump sum as that would be a huge tax event. You could potentially roll it over in chunks (to an RRSP), but I would only do this working with a cross-border CPA as it’s complicated and there’s a risk of double taxation. You could just leave it in the US and withdraw from it as needed, but you may want to file form W-8 BEN to address the withholding tax rate.

      And you’re right that the SEPP 72t rules can be a way to avoid the early withdrawal fee, but these come with very strict rules about the amount you can withdraw and would not be an effective way to move the whole thing.

      Again, this can be complicated and I would encourage you to work with an expert if you decide to go in this direction. If you’re not interested in working with a wealth manager, you could look for an advice-only or fee-only planner who is willing to do hourly or project-based work. Good luck!

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