Are you wondering if you could move your 401k investments in the United States to Canada? The answer is yes. However, you need to know the tax implications on both sides of the border before you make your decision, We are trying to outline here those tax implications.
Notes to Canadian Resident with US income and 401(k) Contribution
Subject to certain conditions, your contribution to 401(k) is deductible from your income in the United States and in Canada when you report your US income on your Canadian Tax return in the year in which you have contributed. However, the extent of the 401(k) deductions you claim on your Canadian tax return will reduce your RRSP contribution limit accordingly. Different rules apply to your IRA contribution and are not deductible on your Canadian tax return.
Suppose you are moving permanently from the United States to Canada. In that case, you have the option to transfer your savings in 401(k)s and IRAs (Individual retirement account) to your RRSPs (Registered retirement saving plan) in Canada.
You do not have an option to transfer your RRSP to IRAs if you are moving from Canada to the United States.
First, let’s know a little more about the RRSP, IRA, and 401(k) retirement plans available in Canada and the United States. This will help you understand, first the tax implications in the country-specific in which your savings are deposited. Then you can investigate the best time and option to withdraw and the possibility of transferring it.
To know more about the country-specific plans, please visit our following blogs:
Having read the above blogs, we will be focusing our discussions on the Traditional IRA or 401(k) from here onwards.
Now let’s discuss the process of transferring your 401(k) or IRA money to your Canadian RRSP.
The above transfer is reported as your income on your Canadian tax return. However, you get an offset as your RRSP deductions when you enter the amount on Schedule 7 on your Canadian tax return.
Since it is a transfer, the RRSP deductions claimed on above Schedule 7 will not affect your RRSP usual contribution limit or room.
Now let’s look at your US tax implications.
Now let’s look at your Canadian tax implications.
Now let’s take an example that you have $100k in your 401(k) and or IRA in the United States. You want to transfer this amount to your Canadian RRSP. If you look closely, you are reporting on your Canadian tax return a net taxable income of $15k. However, you will not have to pay tax on this income as you have more than enough foreign tax credit available. This more than enough foreign tax credit is a waste. The reason is that you can only apply your foreign tax credit to offset the Canadian income tax payable on your above $15k income. You can not use the remaining foreign tax credit to offset your income tax payable on your other sources of income reported on your Canadian tax return. Furthermore, CRA does not allow you to carry forward this unused foreign tax credit to the following year.
Another important aspect is to consider the early withdrawal penalty in the United States. If you have not reached the age of 59 ½ years, you will be subject to a 10% early withdrawal penalty for withdrawing funds from your 401(k) and or IRA in the United States. However, earlier CRA did not allow this 10% penalty to be reported as a foreign tax credit on your Canadian tax return. But now CRA has changed its position and has allowed this 10% penalty to be reported as a foreign tax credit.
But again, the main question that remains is the more than enough foreign tax credit. A great deal of planning involves utilizing this credit on your Canadian tax return.
RKB Accounting is here to help you! We are specialized in cross-border taxation. We always establish a long-term relationship with our clients. This long relationship allows us to minimize your taxes for short periods and in the long run. We always look at your long-term tax planning before advising on your current year’s tax issues.
Disclaimer: Information in the blog/post/article has been presented for a broad and simple understanding. This is not legal advice. RKB Accounting & Tax Services does not accept any liability for its application in any real situations. You need to contact your accountant or us for further information