Hundreds of Americans are arriving in Nanaimo, British Columbia for the second annual Nanaimo Infusion event. And unlike last year’s inaugural gathering — which drew an estimated 300 to 500 visitors — organizers say 2026 is shaping up to be significantly bigger.

As CTV News Vancouver Island reported, “It happened again, even more than last year. More and more Americans working, particularly in the medical field, have made it clear that they have come north because of what they heard about Nanaimo through Infusions. There was a trend that continues to grow this year.”

The standout number: “Roughly half of Americans who have registered are healthcare workers,” according to the broadcast — nurses, doctors, and allied health professionals who aren’t just visiting. They’re scouting.

From Viral TikTok to National Movement

The Nanaimo Infusion started with Tod Maffin — a Nanaimo resident who, alongside his wife Jocelyn, posted a viral TikTok in early 2025 inviting Americans to come visit their city. The pitch was simple: come spend money at local businesses and see what life in Canada is actually like.

That first event in April 2025 exceeded every expectation. Hundreds showed up. Locals signed up for the “Adopt a Visitor” program — picking people up from the ferry, showing them around town, and giving them an unfiltered look at daily life on the island.

But what Maffin didn’t anticipate was the demographic that kept showing up: healthcare workers.

He pivoted. He created Healthcare Infusion — a dedicated offshoot connecting American medical professionals with Canadian communities that are desperate for help. As CTV reported, Maffin “has created a template for — it’s now a national movement with I think 43 chapters across the country.” All run by local volunteers. The Healthcare Infusion Discord community has grown to over 1,600 members as of early 2026.

Maffin has been blunt about what’s driving the trend: “I think a lot of health-care workers are feeling really burnt out and ground down by the American health-care system.” He added, “They’re really relieved to have a way to use their skills and get out of the current political system.”

Nanaimo Mayor Leonard Krog called the movement “innovative, dramatic and patriotic.”

The Recruitment Numbers Tell the Story

Since British Columbia launched its U.S. healthcare recruitment campaign in March 2025, over 400 American-trained healthcare professionals have made the move to the province — 89 physicians, 260 nurses, 42 nurse practitioners, and 23 allied health workers.

Island Health, which serves Nanaimo and the surrounding region, has welcomed 97 of those professionals alone — the second-highest regional total in BC.

The pipeline is even larger. More than 1,300 American clinicians have registered to practice in the province. US nurse registrations with BC’s regulatory colleges jumped eightfold in a single year. American physician registrations rose 145 percent. The province’s streamlined credential recognition process, introduced in 2025, has been a major factor in accelerating the trend.

This Weekend in Nanaimo

The 2026 event runs April 24–26. Visitors will be wearing red lanyards so locals can identify them and welcome them.

As one organizer told CTV, “We want them out in the community, eating in our restaurants, shopping in our stores, staying in our campgrounds. And if you want to show people around, you can register to adopt a visitor.”

A group photo is planned for Saturday afternoon at Maffeo Sutton Park. Information tables will cover healthcare jobs, immigration pathways, local schools, housing, and community life. More details are available on the Nanaimo Infusion website.

A Bigger Trend Underneath

The Infusion is happening against a broader backdrop. BC’s overall population actually shrank last year — the province lost 41,000 people, a decline not seen since the mid-1800s, driven largely by federal cuts to temporary immigration. But within that contraction, American professionals — particularly in healthcare — are moving against the current.

CTV’s reporting on BC’s population decline noted that “over half a million people have come to British Columbia since 2020,” and BC Jobs Minister Ravi Kahlon suggested the pullback could ease pressure on healthcare, education, and housing. But communities like Nanaimo are making it clear: the right kind of immigration isn’t just welcome — it’s being actively recruited.

The Nanaimo Infusion started as a TikTok invite. Two years later, it’s a 43-chapter national movement with real numbers behind it. Whether it becomes a lasting pipeline or a moment in time, the healthcare workers showing up this weekend aren’t just tourists. They’re making plans.

The post The Nanaimo Infusion Is Back — And This Time, American Healthcare Workers Are Leading the Charge appeared first on Beacon Hill Wealth Management.

Hi Phil,

My name is David and I found your website through the Americans in Canada Facebook group. My wife Sarah and I are both 58, currently living in Scottsdale, and we’re seriously planning to move to Vancouver next year to be closer to our grandkids. Sarah’s sister has been in North Van for about 15 years now and keeps telling us what a great lifestyle it is.

I spent most of my career in pharmaceutical sales and did well — I have about $1.2M in a traditional IRA at Schwab, plus another $180K in an old 401(k) from a company I left years ago. Sarah has about $300K in her own IRA. We also have a taxable brokerage with roughly $800K in it. Our house here in Scottsdale is worth about $950K and we plan to sell before we go.

I keep hearing people in the Facebook group say I should convert my IRA to a Roth before I become a Canadian resident. My accountant here in Arizona — good guy, been using him for 20 years — doesn’t really know much about Canadian tax and sort of shrugged when I asked. He suggested I talk to someone who specializes in this.

Is a Roth conversion before the move actually worth the upfront tax hit? I’m worried about writing a $300K check to the IRS in one year just to avoid some theoretical future Canadian tax. And should I be converting Sarah’s IRA too, or just mine? What am I looking at in terms of timing — do I need to get this done a full year before the move, or can I do it right before we cross the border?

Sorry for the long email — just trying to get my arms around this.

Thanks for any guidance,
David

Phil’s Answer

Hi David,

Great question, and your instinct is right — this is one of the most important things to get sorted before you become a Canadian tax resident.

Generally speaking, converting your traditional IRA to a Roth before you establish Canadian residency is one of the biggest planning opportunities we see. Here’s why: once you’re a Canadian resident, any conversion triggers tax in both countries — you’ll pay US tax on the conversion amount, and Canada will generally want their share too, since they treat it as income.

If you do the conversion while you’re still only a US tax resident, you’ll pay the US tax (roughly 24-32% on $1.2M depending on how you spread it out), but Canada isn’t in the picture yet. Once the money is in the Roth and you move to Canada, future growth and withdrawals are generally tax-free in both countries under the treaty — that’s a huge long-term win.

The timing piece is important. You don’t have to convert it all in one year — and frankly, you probably shouldn’t. A lot of our clients will do partial conversions over 2-3 years before the move to manage the tax brackets. The key is getting it done before you’re a Canadian resident for tax purposes. And yes, you should absolutely look at converting Sarah’s IRA too — the same logic applies.

That old 401(k) should be rolled into a traditional IRA first (tax-free rollover), then you can include it in the conversion strategy.

One thing to flag — your Arizona accountant is probably great for domestic returns, but cross-border planning is a whole different animal. You’ll want someone who understands both the 1040 side and the T1 side, especially when it comes to the treaty election under Article XVIII.

Hope that helps — happy to walk you through the numbers on a call if you’d like.

Regards,
Phil Hogan, CPA, CA
phil@beaconhillwm.ca

Related Articles

• Can I Keep My US Brokerage Account After Moving to Canada?
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If you need help with your cross-border tax and investment planning, click here to get started — we’d love to help.

The post Should I Convert My IRA to a Roth Before Moving to Canada? appeared first on Beacon Hill Wealth Management.

Hi Phil,

I’ve been living in Vancouver for about 5 years now — moved from Chicago in 2021 when my husband (Canadian) and I decided to settle on his side of the border. I’m 43, work remotely as a marketing director for a US company (they know I’m in Canada and are fine with it), and I have Canadian PR.

I just found out I was supposed to be filing something called an FBAR. Honestly, I had absolutely no idea this existed until someone posted about it in the Americans in Canada Facebook group last week. I went down a rabbit hole reading about it and now I’m losing sleep over it.

Here’s what I have in Canada: a joint chequing account with my husband at TD (usually about $15K in it), a savings account at EQ Bank with about $45K, an RRSP with about $90K that my employer contributes to, and a TFSA with about $35K — which I’m now reading might be its own separate problem.

On the US side, I still have a checking account at Chase with maybe $5K and a Roth IRA with about $40K from before I moved.

So my Canadian accounts probably total around $185K when the RRSP is included. I’ve been filing my 1040 every year — I use a CPA in Illinois who’s done my returns since before the move — but she’s never once asked me about foreign bank accounts or any form called an FBAR. I feel like I should have been told about this.

Am I in trouble? What kind of penalties are we looking at? Is this the kind of thing where the IRS is going to come after me, or is there a way to fix it quietly?

Thanks,
Stephanie

Phil’s Answer

Hi Stephanie,

Don’t panic — you’re not the first person to discover FBAR requirements a few years late, and there are good options for getting caught up.

Yes, as a US citizen, you’re required to file an FBAR (FinCEN Form 114) every year if the aggregate value of your foreign financial accounts exceeds $10,000 USD at any point during the year. Since you’re living in Canada with $185K+ in Canadian accounts, you’ve been over that threshold since day one.

The FBAR is filed electronically through the BSA E-Filing system — it goes to FinCEN, not the IRS, and it’s separate from your tax return. The deadline is April 15 with an automatic extension to October 15.

Now, here’s the important part about catching up. If your failure to file was non-willful (meaning you simply didn’t know about the requirement, which is clearly your situation), you can likely use the Streamlined Filing Compliance Procedures to get current. Since you live in Canada and likely meet the physical presence test, you’d qualify under the Streamlined Foreign Offshore Procedures, which means:

• 3 years of amended or delinquent tax returns (1040s)
• 6 years of delinquent FBARs
• A certification statement explaining why you didn’t file
• And here’s the best part — no penalty at all if done properly and accepted.

The accounts that go on the FBAR include your TD chequing, EQ savings, RRSP, and TFSA — basically any account you have signature authority over. Your US accounts don’t go on the FBAR since they’re domestic.

You’re right that the TFSA is a separate issue — we should talk about that. But one thing at a time.

And yes, your CPA should have asked about this. It’s a standard question for any US citizen living abroad. You may want to consider working with someone who specializes in cross-border filing going forward.

The worst thing you can do is ignore it now that you know. The penalties for willful non-filing can be up to $100,000 or 50% of the account balance per violation. But for non-willful cases like yours, the path forward is very manageable.

Hope that helps, Stephanie. This is something we handle regularly — happy to help you get squared away.

Regards,
Phil Hogan, CPA, CA
phil@beaconhillwm.ca

Related Articles

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If you need help with your cross-border tax and investment planning, click here to get started — we’d love to help.

The post Do I Still Need to File FBAR if I Live in Canada? appeared first on Beacon Hill Wealth Management.

Hello Phil,

My financial advisor in the US mentioned something about a “cost basis reset” when you move to Canada but he couldn’t explain the details — he said it was “a Canadian thing” and I should find someone who knows that side of it. We found your name through the Americans in Canada Facebook group and watched a couple of your videos. Very helpful.

I’m 60, my wife Margaret is 58, and we’re moving from San Diego to White Rock, BC next March. Margaret is originally from Langley and has family all over the Lower Mainland, so we’ve been going back and forth for years. We finally decided it’s time — our youngest just graduated from college and there’s nothing keeping us in California anymore.

We have a taxable brokerage account at Fidelity with about $2M in it — mostly individual stocks, some blue chips we’ve held for 15+ years. Apple, Microsoft, Amazon — some of these positions have tripled or more. The original cost basis on the portfolio is probably around $700K total, so we’re sitting on roughly $1.3M in unrealized gains. We’ve been avoiding selling because we didn’t want to trigger the capital gains in California (state tax on top of federal).

We also have about $400K in a bond fund, $150K in cash, and our retirement accounts (two IRAs totaling about $900K and a Roth with $200K).

Margaret’s cousin told us that Canada “gives you a fresh start on the cost basis” and that the $1.3M in gains basically disappears for Canadian tax purposes. That seems too good to be true, and I’ve learned to be skeptical when something sounds that good. Can you explain how this actually works?

Thank you,
Patricia

Phil’s Answer

Hi Patricia,

It’s not too good to be true — it’s one of the genuine planning benefits of moving to Canada, and it’s actually really important to get right.

When you become a Canadian tax resident, Canada treats you as having acquired all of your property at fair market value on the date you arrive. This is called the “deemed acquisition” rule. So for Canadian tax purposes, your cost basis on that Fidelity account resets to whatever the stocks are worth on the day you become a Canadian resident.

Here’s why that matters: let’s say you bought Apple at $50 and it’s worth $200 on the day you arrive in Canada. For Canadian purposes, your cost is now $200. If you later sell it at $250, Canada only taxes the $50 gain that accrued while you were a Canadian resident — not the full $150 gain from your original purchase.

Now, the US side is different. The US uses your original cost basis ($50 in this example). So when you sell, the US sees a $200 gain. You’ll need to carefully coordinate the foreign tax credits between the two countries to avoid double taxation on the portion of gain that Canada doesn’t tax.

A few important things to note:

This step-up does NOT apply to certain property like Canadian real estate you might already own, and it does NOT apply to retirement accounts (IRAs, 401(k)s, Roths). Those are handled under their own treaty rules. So your $900K in IRAs and $200K Roth don’t get this benefit — but they don’t need it since they have their own treaty protections.

The bond fund and cash don’t benefit much from the step-up either (minimal unrealized gains), but they still need to be documented.

You absolutely need to document the fair market value of every position on your arrival date. Get account statements dated as close to your move date as possible. If you don’t have this documentation, reconstructing it later is a nightmare — I’ve seen people spend thousands in accounting fees trying to figure out what their cost basis should have been.

Also worth mentioning — if you have positions with large unrealized losses, you might want to consider selling those before you move, because once you get the Canadian step-up, those losses disappear for Canadian purposes.

Hope that helps, Patricia. Happy to walk through the specifics with you and Margaret.

Regards,
Phil Hogan, CPA, CA
phil@beaconhillwm.ca

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If you need help with your cross-border tax and investment planning, click here to get started — we’d love to help.

The post What Is the Cost Basis Step-Up When Moving to Canada? appeared first on Beacon Hill Wealth Management.

Hi Phil,

I’ve been following your YouTube channel for a few months now and it’s been incredibly helpful — especially the video about the 5 biggest mistakes people make when moving to Canada. My wife Laura and I are both 63, currently in Denver, and we’re moving to Victoria this summer. We’ve been vacationing on Vancouver Island for years and finally pulled the trigger — bought a place in Oak Bay last month.

We’ve got our financial life spread across three brokerages: Schwab (about $1.1M — our main taxable account), Vanguard (about $400K — mostly index funds and bond funds), and a small account at TD Ameritrade with about $80K that Laura uses for some individual stock picks she likes to manage. We also have IRAs at Schwab — mine is about $600K and Laura’s is about $350K.

I called Vanguard last week to let them know about our move and ask about updating our address, and the woman on the phone basically said they’re going to freeze our account once we have a Canadian address. She said we’d be restricted to “liquidation only” — meaning we can sell but can’t buy anything new. She wasn’t rude about it but it was clear this wasn’t negotiable.

Schwab seems more flexible based on what I’ve read online, but I’m not sure anymore. And TD Ameritrade — aren’t they part of Schwab now? Laura is really upset about potentially losing access to her account. She’s been managing that portfolio for 10 years and has done well with it.

Is this a real problem? Can they just lock us out of our own money? And what are our options if they do?

Worried,
Greg

Phil’s Answer

Hi Greg,

Unfortunately, yes — this is a very real issue, and you’re smart to be dealing with it before the move rather than after.

Here’s what’s happening: many US brokerages and custodians are not licensed to serve clients with foreign addresses. When you notify them of a Canadian address, their compliance department flags the account. Depending on the firm, they’ll either restrict your account to liquidation-only (meaning you can sell but not buy), freeze it entirely, or in some cases close it and mail you a check.

Vanguard is one of the strictest — they generally will not maintain accounts for Canadian residents, period. Schwab has been more accommodating in the past, but their policies have tightened over the years and it’s not guaranteed. TD Ameritrade was indeed acquired by Schwab, so they’ll follow the same policies — Laura’s account will likely face the same restrictions.

This is something we deal with regularly. The solution is to move your assets to a custodian that’s specifically set up to work with cross-border clients. Our clients’ US-based assets (IRAs, Roth IRAs, taxable accounts that need to stay in US dollars) are typically held at a custodian that’s comfortable working with Canadian residents and understands the reporting requirements on both sides.

A few things to keep in mind:

• Start the transfer process well before your move date — account transfers can take 2-4 weeks
• You’ll want to avoid selling positions just to move custodians (this would trigger capital gains unnecessarily) — in-kind transfers are the way to go
• Make sure the new custodian can handle the specific account types you need (IRA, Roth, taxable, joint, etc.)
• Laura can still manage her individual stock positions at the new custodian — she won’t lose that ability
• Once you’re settled in Canada, your Canadian-dollar investments (RRSPs, TFSAs if applicable, taxable CAD accounts) should generally be with a Canadian custodian

The worst scenario is getting locked out of your accounts mid-move with no plan B. I’ve seen it happen, and it’s stressful.

Hope that helps, Greg. Happy to walk you through the transition plan.

Regards,
Phil Hogan, CPA, CA
phil@beaconhillwm.ca

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If you need help with your cross-border tax and investment planning, click here to get started — we’d love to help.

The post Can I Keep My US Brokerage Account After Moving to Canada? appeared first on Beacon Hill Wealth Management.

If you’re an American living in Canada, you’ve probably heard the advice: “Just file your Canadian return first, then do your US return.” In a lot of cases, that works. But if you have investment income, US rental properties, or US-source dividends, filing in the wrong order can cost you thousands — and trigger a CRA review you didn’t see coming.

In this episode, Phil Hogan breaks down exactly when filing your Canadian return first works, when it doesn’t, and why the foreign tax credit calculation is where most people get burned.

When Filing Your Canadian Return First Actually Works

If your tax situation is straightforward — you’re employed in Canada, you have a T4, and no investments — filing the Canadian return first is perfectly fine. You report your Canadian employment income, file the return, then hand everything to your US preparer.

On the US side, your preparer reports the T4 income on the 1040 and either claims a foreign tax credit for Canadian taxes paid, or uses the Form 2555 Foreign Earned Income Exclusion to wipe out the US tax. Two options, both work well for simple returns.

Simple Return = Flexible Filing Order

If you only have Canadian employment income (T4) and no investments, rental income, or US-source income, you can safely file your Canadian return first and your US return second. The foreign tax credit math is straightforward.

When It Falls Apart: Investment Income, Rentals, and US Dividends

Here’s where it gets tricky. Let’s say you’re an American living in Canada with:

• T4 employment income from your Canadian job
• A rental property in Florida generating net rental income
• An investment portfolio with both Canadian and US dividends

If you file the Canadian return first, you’d report your worldwide income — employment, rental income, capital gains, interest, and dividends. Then you’d need to claim a foreign tax credit for US taxes paid on that US-source income.

But here’s the problem: how do you know what your US taxes are if you haven’t filed your US return yet?

The Foreign Tax Credit Trap

Many people claim a foreign tax credit based on the withholding tax shown on their slips (often 15%, the treaty rate). But your actual US tax on that income may be less than 15% — especially if you’re not in a high income bracket. And for US rental income, you have no idea what the tax will be until the 1040 is prepared. Filing the Canadian return with incorrect foreign tax credits is one of the most common cross-border mistakes.

What Happens When the CRA Reviews Your Foreign Tax Credit

This is the part most people don’t see coming. After you file your Canadian return, the CRA frequently sends a review letter asking you to prove your foreign tax credit calculation.

They’ll ask for:

• Your detailed foreign tax credit calculation
• A copy of your US 1040 return
• Your US 1040 transcript

If the amount of US tax you actually paid on your 1040 doesn’t match what you claimed as a credit on your Canadian return, the CRA will reassess you. If you overstated your foreign tax credit, you’ll get a bill for the difference — plus interest.

Why This Happens So Often

The CRA knows that foreign tax credit claims are frequently wrong. That’s why they audit them regularly. The root cause is almost always the same: the Canadian return was filed before the US return was complete, so the foreign tax credit was based on estimates or withholding amounts instead of actual US tax paid.

The Right Approach: File Both Returns in Tandem

The solution isn’t necessarily that the same person does both returns — although that’s ideal. The key is: do not file your Canadian return before your US return is at least started or in process.

When both returns are prepared together, the preparer can:

• Calculate the actual US tax on each income source
• Apply the correct foreign tax credit on the Canadian return
• Avoid the back-and-forth between separate preparers
• Prevent CRA reassessments down the road

In Phil’s experience, when a Canadian preparer does the T1 and a separate US preparer does the 1040, you often end up with weeks of back-and-forth — emails, phone calls, revised calculations — all of which is completely avoidable if the returns are prepared under one roof.

Separate Preparers = Coordination Risk

Even if both preparers are competent, the coordination overhead is real. Weeks of going back and forth on foreign tax credit calculations by email is an inefficient and error-prone way to handle cross-border returns. One firm handling both sides eliminates this entirely.

The Bottom Line

“File your Canadian return first, then your US return” is advice that works for simple situations — and fails for everything else. If you have investment income, US rental properties, US dividends, or any US-source income, your Canadian and US returns need to be prepared together, or at minimum, in close coordination.

The foreign tax credit is the linchpin of cross-border tax filing. Get it wrong, and you’re looking at CRA reassessments, interest charges, and a lot of unnecessary stress. Get it right by filing both returns in tandem — ideally under one roof.

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Disclaimer: This content is for informational purposes only and does not constitute legal, tax, or investment advice. Tax and financial planning rules change frequently and some information may be outdated. The views expressed are those of Beacon Hill Wealth Management Ltd. and may change without notice. Past performance is not indicative of future results. Investing involves risk, including possible loss of principal. Please consult a qualified cross-border tax and financial planning professional for advice specific to your situation.

The post Why Filing Your Canadian Return Before Your US Return Can Cost You Thousands appeared first on Beacon Hill Wealth Management.

Hi Phil,

I found your website through the Americans in Canada Facebook group and I’m hoping you can help with something that’s been on my mind.

My wife is originally from Vancouver and we’ve been living in Arizona for about 18 years. She’s a dual citizen and I’m American. We’re both 61 and planning to move back to BC sometime in the next year or so — probably around next spring once we sell the house here.

I have a traditional IRA worth roughly $1.8 million and my financial advisor here mentioned something about converting some of it to a Roth before we make the move. He wasn’t really sure about the Canadian side of things though and honestly I don’t think he fully understands the cross-border implications.

My question is whether this Roth conversion strategy actually makes sense for someone in our situation and if so, how much should we be looking at converting? I don’t want to pay a huge tax bill right now if it’s not going to save us anything on the Canadian side down the road.

Any guidance would be really appreciated. We’re feeling a bit overwhelmed with all the moving parts here.

Thanks,
XXXXX

Answer

Hi XXXXX,

Thanks for reaching out — and I completely understand feeling overwhelmed. There are a lot of moving pieces when you’re planning a cross-border move, especially with the size of your IRA. I actually wrote a detailed article on this exact topic that you might find helpful: Moving to Canada with a Large IRA.

The short answer is yes, in most cases a Roth conversion before becoming a Canadian tax resident can make a lot of sense. Here’s why.

Once you become a Canadian tax resident, your traditional IRA distributions — including your required minimum distributions — will generally be fully taxable on the Canadian side. You’ll get a foreign tax credit in Canada for the US tax you pay, but that credit is typically capped at 15% under the treaty. So if your Canadian marginal rate is, say, 45%, you’re looking at a significant gap that the foreign tax credit won’t cover.

By converting some of that IRA to a Roth before you enter Canada, you’ll pay US tax on the conversion at your current US rate. For many clients, that rate ends up being considerably lower than what they’d pay on the Canadian side later on. So the tax you pay now on the conversion is often much less than the tax you’d pay in the future on those same IRA distributions.

As for how much to convert — it really depends on your overall income picture in the year before you move. Generally speaking, you’d want to convert enough to take advantage of the lower US brackets without pushing yourself into a bracket that eliminates the benefit. We typically work through the numbers with clients to find that sweet spot.

A couple of other things to keep in mind:

• Make sure you’re over 59½ (which you are) to avoid early withdrawal penalties on the conversion.
• The conversion needs to happen before you become a Canadian tax resident. Once you’re in Canada, the math changes significantly.
• You’ll also want to look at your taxable investment accounts and consider making them joint before the move for income-splitting purposes on the Canadian side. That’s another area where we can often save clients a fair amount of tax.
• Once you’re in Canada, it’s important to understand how your Roth IRA is treated for Canadian tax purposes — there are some specific treaty elections that need to be filed to maintain the tax-free status.

I’d strongly recommend sitting down with a cross-border advisor to map this out properly — there’s a lot of value in getting the planning right before you make the move, because many of these opportunities disappear once you become a Canadian resident.

Hope that helps, and don’t hesitate to reach out if you’d like to discuss your situation in more detail.

Regards,
Phil Hogan, CPA, CA
phil@beaconhillwm.ca

If you’re planning a move to Canada and need help with your cross-border tax and investment planning, click here to get started — we’d love to help.

The post Should I Convert My IRA to a Roth Before Moving to Canada? appeared first on Beacon Hill Wealth Management.

What Changed: Canadian Passport Fee Increases (March 31, 2026)

On March 31, 2026, the Government of Canada increased passport and travel document fees for the first time since 2013. The increases were announced on March 3, 2026 by Immigration, Refugees and Citizenship Canada (IRCC).

The standard increases are modest — roughly 2% across the board. But the bigger story is what comes next: fees will now be adjusted annually under the Service Fees Act, pegged to the Consumer Price Index. The era of 13-year freezes is over.

Why Now?

The Service Fees Act requires federal fees to be periodically updated to reflect actual service costs. Passport fees were among the last major government fees that hadn’t been touched in over a decade. In that time, the cost of producing RFID-chipped biometric passports has risen substantially.

The New Fee Schedule

Passports for Canadians Living in Canada

Passports for Canadians Living Outside Canada

If you’re applying from outside Canada (through a consulate or embassy), fees are higher — and always have been:

Urgent Services: Where the Real Increases Hit

The headline numbers are small, but if you need a passport in a hurry, the increases are much steeper — 11% to 14%:

Plan Ahead

The premium for last-minute passport services just got significantly more expensive. A weekend rush passport now costs $383.50 — that’s nearly 2.5x the regular fee. Renew well before your passport expires.

The Silver Lining: 30-Day Processing Guarantee

Starting April 1, 2026, IRCC introduced a new service standard: complete passport applications will be processed within 30 business days. If they miss this target, your passport is free — with refunds issued automatically. No paperwork, no chasing anyone.

If you remember the post-COVID passport chaos of 2022 — months-long waits, lineups around the block at Service Canada offices — this is the government’s direct response. It’s a meaningful accountability measure.

Automatic Refund

If processing exceeds 30 business days, you don’t need to do anything — the refund is issued automatically. This is a significant new consumer protection for Canadian passport holders.

What This Means for Americans Living in Canada

Here’s where it gets interesting for our cross-border community.

The Dual Passport Cost

If you’re a Canadian-American dual citizen, you need to maintain both passports:

• Canadian passport: Required to fly back to Canada. No exceptions — even if you’re a dual citizen, even if you’re just transiting through.
• US passport: Required to enter the United States. American citizens must enter and exit the US on their American passport.

That means you’re paying two countries every 10 years:

The Bigger Picture

For a married couple, that’s roughly $500 USD ($690 CAD) per decade just to keep your travel documents current. Not a fortune, but it’s one of those quiet costs of dual citizenship that adds up alongside your two tax returns, two sets of financial reporting, and two estate plans.

Canada Is Still a Bargain

For all the talk of fee increases, Canadian passports remain significantly cheaper than American ones. A new US passport book costs $165 USD ($229 CAD) including the facility fee, compared to just $163.50 CAD for the Canadian equivalent. Even with annual increases going forward, Canada has a long way to go before reaching parity.

US vs. Canada: Fee Comparison

Pro Tip

The US now offers online passport renewal. If your passport is eligible, you can skip the in-person visit entirely. Canada’s online application system has also improved significantly since the post-COVID overhaul.

Annual Increases Are Now the Norm

Under the Service Fees Act, passport fees will now be adjusted each year based on the Consumer Price Index. Current CPI is running 2-3% annually, so expect small annual bumps rather than the old pattern of nothing-for-a-decade-then-a-big-jump.

For planning purposes, this means the cost of maintaining dual passports will creep up predictably each year — another line item in the cost of cross-border life.

Don’t Let Your Canadian Passport Lapse

We see this more than you’d think: American expats who let their Canadian passport (or Canadian citizenship proof) lapse because they “never fly into Canada from outside North America.” Then they book a trip to Europe, and realize they need a valid Canadian passport for the return flight.

With fees now increasing annually, there’s a (very) small cost incentive to renew sooner rather than later. But more importantly, having a lapsed passport creates travel headaches that no amount of money can solve at the last minute — even with the new $383.50 weekend rush service.

Mailed Applications

For mailed applications, the fee is based on the date the application is received, not the date it is mailed. Applications received on or after May 1, 2026 with the old fee will be returned and must be resubmitted with the correct fee.

The Bottom Line

The Canadian passport fee increase itself is small — a few dollars more for standard passports. The real shift is the move to annual inflation-linked adjustments, which ends 13 years of frozen fees and sets a new normal.

For Americans living in Canada, it’s a reminder that dual citizenship comes with dual costs — passports, tax returns, financial reporting, estate planning. Each one is manageable on its own, but together they form a web of obligations that requires proper cross-border planning.

The post Canadian Passport Fees Just Went Up: What Dual Citizens Need to Know (2026) appeared first on Beacon Hill Wealth Management.

Now you’re moving to Canada, and Canadian healthcare is free. Sort of. Mostly. It’s complicated.

The reality of Canadian healthcare for American retirees is considerably more nuanced than the headline suggests. Yes, it covers far more than you might expect. And yes, there are gaps, wait times, and transition challenges that anyone relocating from the US needs to understand clearly. This guide gives you both sides honestly.

How Provincial Health Insurance Actually Works

Canada does not have a single national health plan. It has ten provincial and three territorial plans, each with its own administration, rules, and coverage scope. The federal Canada Health Act sets minimum standards — publicly funded hospital care and physician services must be covered for all eligible residents — but the specifics vary by province.

To become eligible, you must:

1. Be a Canadian citizen, permanent resident, or certain work permit holders
2. Establish residency in a province (rent a home, get a provincial driver’s licence, set up provincial ties)
3. Complete the waiting period — typically 1-3 months depending on your province
4. Register with the provincial health authority and receive your health card

As an American moving to Canada as a permanent resident or dual citizen, you’ll be eligible once you’ve met these requirements. The waiting period is the critical gap: you are not covered the moment you arrive.

Waiting Periods by Province

British Columbia: 3-month waiting period from the date you establish residency. You must apply for MSP (Medical Services Plan) coverage and will receive a confirmation letter. During the wait, private interim insurance is strongly advised.

Ontario: No waiting period for most new residents. OHIP (Ontario Health Insurance Plan) coverage begins when you register. However, you need to provide proof of residency, and the registration process itself can take a few weeks.

Alberta: 3-month waiting period. The province recently eliminated premiums (Alberta no longer charges monthly health premiums), so coverage is fully premium-free once the wait is done.

Quebec: 3-month waiting period, with some exceptions. Quebec also has a mandatory prescription drug insurance plan (RAMQ) that covers basic medications.

Most other provinces: 3-month waiting period is the standard.

What’s Covered — The Good News

Once you have provincial coverage, the scope of what’s included without any payment from you is genuinely impressive by American standards:

• All medically necessary physician visits — GP appointments, specialist consultations, follow-ups. No co-pay, no deductible.
• Hospital care — inpatient stays, surgery, intensive care, maternity. No per-night room charge for standard ward beds.
• Diagnostic imaging and lab tests — MRIs, CT scans, X-rays, blood work. No payment when ordered by a physician and done at a public facility.
• Emergency care — walk-in and emergency room visits are fully covered once you’re enrolled.
• Mental health services — covered when provided by a physician (psychiatrist). Social workers and psychologists are largely not covered except through supplemental plans.

The financial contrast with the US is stark. In the US, a hospital stay that runs $40,000 might leave you with $5,000-$8,000 out of pocket even with good insurance. In Canada, that same stay costs you nothing. For retirees who statistically use healthcare more than younger people, this is not a small difference — it’s a fundamental change in financial exposure.

What’s NOT Covered — The Honest Answer

Canadian provincial health insurance has real gaps. These are the areas where Americans moving to Canada are often surprised:

• Prescription drugs — Outside Quebec (which has RAMQ), most provincial plans do not cover the majority of prescription medications for working-age adults and retirees who aren’t on social assistance. You’ll need either employer coverage (if still working), a private supplemental plan, or you pay out of pocket.
• Dental care — Routine dental is not covered by provincial plans. Cleanings, fillings, crowns, root canals — out of pocket unless you have private insurance. This is a significant gap for retirees.
• Vision care — Routine eye exams are partially covered in some provinces for seniors 65+, but glasses and contact lenses are not covered.
• Physiotherapy, chiropractic, massage — Generally not covered unless provided in a hospital setting as part of post-surgical rehabilitation.
• Ambulance services — In most provinces, ground and air ambulance involve fees. A BC ground ambulance can cost $80+; air ambulance can be thousands.
• Semi-private or private hospital rooms — A standard ward bed is covered; a private room is not.
• Hearing aids and orthotics — Generally not covered.

The practical implication: most Canadians — and almost all Canadian retirees — carry supplemental private health insurance to cover these gaps. Annual premiums for a comprehensive seniors’ supplemental plan typically run $3,000-$6,000 per person depending on age, province, and coverage level. That’s real money, but dramatically less than equivalent US coverage costs.

The Wait Times Question

Wait times are the most commonly cited criticism of Canadian healthcare, and they deserve an honest answer — neither dismissive nor alarmist.

Emergency care: Triage is immediate. Life-threatening conditions are treated as urgently in Canada as anywhere. If you’re having a heart attack in Toronto, you receive equivalent care to Chicago. The wait time issue is primarily in non-emergency contexts.

Specialist referrals: This is where the waits are real. Seeing a specialist in Canada typically requires a GP referral, and wait times vary from weeks to months depending on the specialty, the province, and the urgency classification. A dermatology referral might take 3-6 months. A cardiology referral for a non-urgent concern might take 6-12 weeks. Orthopedic surgery for a non-urgent knee replacement can take 1-2 years in some provinces.

Finding a family doctor: This is the most significant structural problem in Canadian healthcare right now, and it affects returnees disproportionately. Approximately 5 million Canadians don’t have a family doctor. Without a GP, you rely on walk-in clinics, which are fine for acute care but can’t manage chronic conditions the way a longitudinal relationship with a family physician can. If you’re moving to a small city or rural area, finding a GP may take a year or more — or may not happen.

What Americans do about waits: Many cross-border retirees use a hybrid approach — maintaining access to US care for scheduled procedures where waits are unacceptably long (this requires insurance for US care), while using Canadian coverage for all other healthcare. This is a personal financial calculation worth modeling.

What Happens to Your US Medicare

If you’re 65+ and have Medicare, moving to Canada doesn’t cancel it — but it doesn’t help you much either. Medicare covers healthcare services in the US. It does not cover care received in Canada, with extremely narrow exceptions (emergency care at a Canadian hospital that is closer to your location than the nearest US hospital, if you are in the US).

If you stop paying Medicare Part B premiums after moving to Canada and then return to the US years later, you’ll face late enrollment penalties — 10% per year you were not enrolled added permanently to your premiums. The standard advice for Americans moving to Canada who are 65+ is to continue paying Medicare Part B premiums while abroad, so you can return to US coverage without penalty if your circumstances change.

Medicare Part A (hospital insurance) is typically premium-free if you’ve worked 40+ quarters in the US. Keeping it active costs you nothing and preserves your eligibility for US hospital care on return visits.

Medicare Advantage (Part C) plans are private plans that contract with Medicare. They almost universally do not cover care outside the US (except limited emergency). If you move to Canada, a Medicare Advantage plan is effectively useless for day-to-day care. Most people transition to Original Medicare (Parts A and B) with a supplemental Medigap policy if they’re planning significant US visits.

Private Supplemental Insurance in Canada

The private health insurance market in Canada is primarily focused on covering the gaps in provincial coverage — extended health benefits including prescription drugs, dental, vision, and paramedical services. The major providers include Manulife, Sun Life, Great-West Life (Canada Life), Blue Cross, and Green Shield.

For retirees, the key considerations are:

• Pre-existing conditions: Unlike the US post-ACA market, Canadian supplemental insurers can and do impose waiting periods or exclusions for pre-existing conditions. The more significant your medical history, the more carefully you need to read the policy terms.
• Continuous coverage: Most insurers offer better terms if you’re transitioning from group coverage (e.g., from an employer plan) without a gap. If you retire and let your US group coverage lapse without immediately picking up Canadian coverage, you may face stricter underwriting.
• Drug formularies: Plans vary significantly in which prescription drugs they cover and at what percentage. If you take expensive specialty medications, verify formulary coverage before choosing a plan.
• Travel insurance: Many supplemental plans include limited out-of-country emergency coverage — typically 60 or 90 days. If you plan to spend significant time in the US (visiting family, wintering in the South), you may need standalone travel health insurance.

Our complete guide to health insurance for Americans in Canada covers supplemental plan options in detail, including what to look for and how to compare plans for your specific situation.

Canada’s New Pharmacare Program

In 2024, Canada passed the Canada Pharmacare Act, beginning the rollout of a national pharmacare program — a major shift in how prescription drugs will eventually be covered across the country. The initial phase covers diabetes medications and contraceptives. The longer-term vision is a universal formulary covering essential medications for all Canadians.

As a practical matter for retirees moving to Canada in 2025 and 2026, pharmacare is still in its early stages. It does not yet replace the need for supplemental drug insurance for most people. But it signals the direction of Canadian health policy, and coverage will expand over the coming years. Staying informed about pharmacare rollout in your province is worth doing.

The Financial Math: A Real Comparison

Let’s put concrete numbers to this. Consider a 65-year-old couple retiring in the US versus Canada:

In the US (Medicare):

• Medicare Part B premiums: ~$2,100/year per person ($4,200/couple)
• Medigap supplemental plan (Plan G): ~$3,000/year per person ($6,000/couple)
• Medicare Part D (drugs): ~$600/year per person ($1,200/couple)
• Dental insurance (limited): ~$800/year per person ($1,600/couple)
• Estimated annual out-of-pocket even with this coverage: $2,000-$5,000/couple in a typical year
• Total annual healthcare cost: $15,000-$18,000 per couple

In Canada (BC, as an example):

• Provincial MSP: $0 (premiums eliminated in 2020)
• Supplemental private plan (extended health + dental): ~$4,000/year per person ($8,000/couple at age 65+)
• Prescription drugs above what supplemental covers: ~$500-$1,000/couple/year
• Out-of-pocket for dental above plan limits: variable
• Total annual healthcare cost: $9,000-$12,000 per couple

The gap is significant — roughly $5,000-$8,000 per year for a typical couple. Over a 20-year retirement, that’s $100,000-$160,000 in savings, before accounting for the catastrophic event protection that comes with no US deductibles or out-of-pocket maxima.

Emergency Care and Travel

One practical consideration often overlooked: what happens when you’re traveling back to the US to visit family?

As a Canadian resident, your provincial plan generally does not cover you when you’re outside Canada (some plans have very limited out-of-country emergency coverage for short trips). If you spend significant time in the US — and many cross-border retirees do, especially those with family there — you need US travel health coverage.

Options include: stand-alone travel health insurance, continuing Medicare Part B (which covers you in the US), or purchasing a US plan for extended stays (though this becomes complex if you’re spending more than 6 months/year in the US, as that starts to affect your Canadian tax residency status).

The transition experience of your first year in Canada covers much of this practical complexity — including how other returnees have navigated the dual-country healthcare reality in practice.

Pre-Existing Conditions

Provincial health insurance in Canada covers all eligible residents regardless of pre-existing conditions. There are no exclusion periods for provincial coverage — if you need care for a condition you arrived with, the province covers it once you’re enrolled.

Private supplemental insurance is different. Insurers can and do impose waiting periods and exclusions for pre-existing conditions. If you have a chronic condition that requires expensive medications or regular specialist care, you need to read supplemental plan terms carefully and potentially work with an insurance broker who understands the Canadian market.

For US citizens who moved to Canada with pre-existing conditions that were difficult or expensive to insure in the US, the provincial coverage reality is genuinely transformative. The condition that cost you $15,000/year in the US costs you, for physician and hospital care, nothing in Canada.

Making the Transition Smoothly

Based on the experience of hundreds of cross-border relocations, here’s what we recommend for healthcare transition planning:

1. Arrange interim insurance before you arrive. The waiting period is real. Private interim coverage typically runs $200-$400/month for a single person and is worth every dollar.
2. Register for provincial health immediately upon arrival. Don’t wait. Get your documentation together and register on day one.
3. Start looking for a family doctor before you arrive. Many provinces have online family doctor registries. Being on the waitlist before you land can shorten the time to getting a GP.
4. Bring a complete medical history. Your Canadian doctors cannot access US medical records. Bring summaries of conditions, medication lists, specialist reports, and recent test results.
5. Review your Medicare status. If you’re 65+, understand what to keep active and what to suspend. The penalty structure for late re-enrollment is real.
6. Purchase supplemental insurance promptly. Once your provincial coverage kicks in, don’t delay getting supplemental coverage for drugs, dental, and vision.

The Bottom Line

Canadian healthcare for American retirees is genuinely better in ways that matter most at retirement: no catastrophic financial exposure from illness, no pre-existing condition discrimination for provincial coverage, and significantly lower annual costs even after supplemental insurance.

The trade-offs — wait times for non-urgent specialty care, gaps in dental and drug coverage, the challenge of finding a family doctor — are real and worth planning for. But for the majority of American retirees who make the move to Canada, the healthcare system is one of the things they’re most grateful for.

At Beacon Hill Wealth Management, we help Americans moving to Canada plan the full financial picture of their transition — healthcare costs, retirement income, tax planning, and investment strategy. Getting the healthcare piece right is part of every client plan we develop.

Talk to a cross-border financial advisor today →

The post Canadian Healthcare vs. US Healthcare: What American Retirees Actually Need to Know Before the Move appeared first on Beacon Hill Wealth Management.

It’s a great question. The honest answer is: it depends on your situation — but for most Americans living in Canada, the answer is yes, and the reasons why matter a great deal.

The United States and Canada have fundamentally different approaches to taxing and transferring wealth at death. When you live in Canada as a U.S. citizen, your estate is simultaneously subject to both systems. Without proper planning, your family could face serial probate delays, double taxation, and administrative gridlock that takes years to untangle.

This article walks through the key concepts every American in Canada needs to understand — including why your existing U.S. will may not be enough, how the two tax systems interact, and what a well-structured plan actually looks like.

The Core Problem: Two Countries, Two Tax Systems, One Estate

When a U.S. citizen living in Canada passes away, their estate is simultaneously subject to two distinct tax regimes — and they work in fundamentally different ways.

How Canada Taxes Death: The Deemed Disposition

Canada does not have an estate tax or an inheritance tax. Instead, the Income Tax Act treats death as a “deemed disposition” — meaning the CRA considers you to have sold all of your capital property at fair market value immediately before you died. Any accrued capital gains are reported on your final (terminal) tax return and taxed at your marginal income tax rate.

For a long-time investor with a large non-registered portfolio, a cottage, or a private company, this deemed disposition can trigger a substantial tax bill.

How the U.S. Taxes Death: The Federal Estate Tax

The United States takes a completely different approach. Rather than taxing gains, the U.S. levies an estate tax on the total fair market value of a deceased U.S. citizen’s worldwide assets — regardless of where they live. This includes real estate, investment accounts, life insurance (if you held incidents of ownership in the policy), and everything else you own globally.

The U.S. federal estate tax exemption for 2026 is currently set at US$15,000,000 per person. While the legislative landscape can change, the exemption level and any future adjustments are important inputs to an estate plan for any U.S. citizen with a sizeable estate. Even below the current threshold, the interaction between U.S. estate tax rules and Canadian deemed disposition on the same assets makes proactive planning essential.

Because Canada taxes the gain and the U.S. taxes the value, the risk of double taxation is real and acute — particularly for those with appreciated U.S. real estate or large investment portfolios. This is why coordinated planning is not optional; it is essential.

Do You Need One Will or Two?

A single will can technically be valid across borders. But for the vast majority of Americans living in Canada, professional consensus strongly favors dual wills: one for Canadian assets and a separate “situs will” for U.S. assets. Here is why.

The Problem with a Single Will

If you use a single Canadian will to cover your entire worldwide estate, your executor faces a serial probate process. They must first complete Canadian probate, and only then can they apply separately for “ancillary probate” or resealing in each U.S. state where you hold assets. This sequential process can freeze your U.S. assets for six to nine months or longer — during which time investments sit idle and taxes come due.

A single will also creates jurisdictional confusion. Canada’s probate courts apply Canadian law; U.S. probate courts apply the law of the relevant state. Attempting to run one document through both systems invites complications that a properly structured dual-will approach avoids entirely.

The Case for Dual (Situs) Wills

Dual wills allow your executors to initiate probate in Canada and the United States simultaneously, dramatically compressing the timeline for your beneficiaries to access assets. They also allow you to appoint different executors for each jurisdiction — which has significant tax implications we cover below. And they eliminate the risk that courts or financial institutions misapply the wrong country’s laws to the wrong assets.

A single Canadian will may be sufficient if your U.S. connections are genuinely minimal — for instance, if you hold only a small IRA and no U.S. real estate. But if you own U.S. property, hold substantial U.S. investment accounts, or have U.S. beneficiaries, dual wills are almost certainly the right approach.

The Most Dangerous Clause in Any Will: The Revocation Clause

Here is the single most common — and most costly — drafting error in cross-border wills: the inadvertent revocation of a foreign will.

Every standard will template begins with a clause along the lines of: “I hereby revoke all former Wills and Codicils.” If you sign a Canadian will with this boilerplate language, and later sign a U.S. will containing the same language, your U.S. will may legally nullify your Canadian will — leaving your Canadian estate to be distributed as if you had no will at all (i.e., under provincial intestacy rules). Your carefully expressed wishes are simply overridden.

The solution is precise, jurisdiction-specific revocation language in each document:

• Your Canadian will should state that it revokes all prior testamentary instruments except those specifically intended to govern U.S. situs property, referencing the U.S. will by date or jurisdiction.
• Your U.S. will should clarify that it applies only to U.S. situs property and does not disturb the Canadian will in any way.

A further refinement used by experienced practitioners: include a clause stating that the U.S. will can only be revoked by a subsequent document that specifically references it by date — providing an extra layer of protection against future boilerplate revocations.

Defining What Goes Where: The Situs Clause

Each will needs to clearly define the assets it governs so that executors are not double-claiming authority or, worse, leaving assets orphaned between jurisdictions.

Pay particular attention to U.S. publicly traded shares held in a Canadian brokerage account. For U.S. estate tax purposes, shares in U.S. corporations are typically treated as U.S. situs assets regardless of where the account statements are physically located. Your U.S. will’s situs clause should explicitly capture these assets.

Who Should Be Your Executor? It Matters More Than You Think

The choice of executor is not just an administrative decision — it has direct tax consequences for your estate.

The Central Management and Control Test

In Canada, the residency of an estate is a question of fact determined by where its central management and control is actually exercised — not simply by the address on an executor’s driver’s licence. In practice, CRA tends to look at where key decisions are made, where records are kept, and where the executor conducts the estate’s affairs. A U.S.-resident sole executor who manages everything from Arizona creates a real risk that CRA treats the estate as non-resident, with potentially serious consequences.

If an estate is determined to be non-resident, the implications can include:

• Loss of Graduated Rate Estate status: An estate that qualifies as a Graduated Rate Estate (GRE) benefits from progressive tax brackets for up to 36 months. A non-resident estate is unlikely to qualify, meaning all income may be taxed at the highest marginal rate.
• Real estate holdback: A non-resident executor selling the deceased’s Canadian property must obtain a CRA Certificate of Compliance — and until it is issued, a significant portion of the gross sale price can be withheld.
• Additional withholding taxes: Various Canadian-source payments made to a non-resident estate may be subject to Part XIII withholding.
• U.S. foreign trust reporting: A U.S. resident executor may trigger IRS reporting obligations on Canadian estate assets, adding accounting fees and potential penalty exposure.

Appointing a Canadian-resident co-executor — ideally someone in BC — who is actively involved in managing the estate is an important step toward ensuring the estate is treated as a Canadian resident. It is not a guarantee on its own, since residency remains a facts-and-circumstances test, but it materially strengthens the position. Your tax advisors should be engaged early to monitor this issue.

Executor Selection and BC Practice

Under WESA, security (a bond) is not automatically required simply because an executor lives outside BC. Section 128 of WESA provides that no security is required unless a minor or incapable person has an interest in the estate, or the court orders otherwise. That said, courts do retain discretion to require a bond in appropriate circumstances, and practical experience shows that non-resident executors can face friction with financial institutions, registries, and the probate process generally.

From a practical standpoint, appointing a BC-resident co-executor on your Canadian will serves multiple purposes: it facilitates smoother interactions with local registries and institutions, supports the case for Canadian estate residency (for tax purposes), and reduces the likelihood of court-ordered security. Your U.S. will can name a separate U.S.-resident executor or professional trust company to handle the American side concurrently.

The Canada-U.S. Tax Treaty: Your Most Important Planning Tool

Article XXIX-B of the Canada-United States Tax Convention provides specific mechanisms designed to prevent double taxation at death. Understanding these provisions is critical — and your will should explicitly authorize your executor to claim every benefit available.

U.S. Estate Tax for U.S. Citizens: Form 706

A U.S. citizen who dies while living in Canada is subject to U.S. estate tax on their worldwide assets under domestic U.S. law — and they file Form 706 (United States Estate Tax Return), not Form 706-NA. Form 706-NA is reserved for decedents who were neither U.S. citizens nor U.S. residents. This distinction matters because a U.S. citizen is entitled to the full unified credit under domestic law, not a prorated share of it.

The Treaty’s prorated unified credit under Article XXIX-B(2) applies specifically to Canadian-resident decedents who are not U.S. citizens — that is, Canadians with U.S. situs assets. For U.S. citizens, the relevant Treaty provisions operate differently, primarily addressing relief from double taxation where both countries are taxing the same assets or the same transfer.

Treaty Relief from Double Taxation for U.S. Citizens

While U.S. citizens do not need the Treaty to access the full unified credit (they have it under domestic law), Article XXIX-B still provides important relief in other ways. Article XXIX-B(6) provides that Canada will allow a credit against Canadian income tax for U.S. estate tax paid on property situated in the United States — helping prevent the same asset from bearing both Canadian deemed-disposition income tax and U.S. estate tax. Article XXIX-B(7) provides a parallel U.S. credit for Canadian income tax paid on assets situated outside the United States.

The interaction of these provisions is technically complex and must be carefully coordinated by your Canadian and U.S. advisors. The executor must file Form 706 within nine months of death (extensions are available). Missing this deadline can cost the estate significant Treaty-based relief and should be treated as a hard deadline from day one.

The Marital Credit and the QDOT

The U.S. unlimited marital deduction allows a surviving spouse to inherit free of estate tax — but only if the surviving spouse is a U.S. citizen. If your spouse is a Canadian non-resident alien, this deduction is unavailable by default, which can create a significant and unexpected tax liability.

The Treaty provides a partial solution through a marital credit under Article XXIX-B(3) and (4): in certain circumstances, additional credit is available when assets are left to a surviving Canadian spouse, effectively increasing the amount sheltered from U.S. estate tax. For very large estates, the will may establish a Qualified Domestic Trust (QDOT), which allows the estate to qualify for the marital deduction by ensuring assets remain within the U.S. tax net through a U.S. trustee, deferring estate tax until the surviving spouse takes a principal distribution or passes away. Whether the Treaty marital credit or a QDOT is the better solution depends heavily on the size of the estate and the citizenship of the surviving spouse — this is an area where specialist advice is essential.

Cross-Border Charitable Giving

The Treaty also allows bequests to Canadian registered charities to be deducted from your U.S. gross estate, provided the charity would qualify for exempt status in the United States. For clients with philanthropic intentions, this is a powerful tool that reduces the tax burden in both countries simultaneously and ensures your generosity is recognized across borders.

What About Your RRSPs, TFSAs, IRAs, and 401(k)s?

Registered accounts and retirement plans pass outside of your will through beneficiary designations — which means they require their own careful cross-border planning.

TFSAs and RESPs: A U.S. Reporting Problem

While TFSAs and RESPs are tax-exempt in Canada, the United States does not recognize them as such under the current Treaty. Income and gains inside a TFSA are taxable annually on your U.S. Form 1040. Worse, the IRS may classify these accounts as “foreign trusts,” triggering onerous annual reporting on IRS Forms 3520 and 3520-A. If you name a U.S. beneficiary on your TFSA, that person may inherit not just cash but a significant reporting obligation.

Inherited IRAs and 401(k)s: The Canadian Beneficiary Problem

When a Canadian resident inherits a U.S. IRA or 401(k), the challenges run in the other direction. Under the U.S. SECURE Act, most non-spouse beneficiaries must fully withdraw inherited IRA funds within ten years of the original owner’s death. Many U.S. financial institutions are unwilling or unable to maintain accounts for beneficiaries residing in Canada due to securities regulations — which can force an immediate lump-sum distribution, triggering tax at the highest marginal rates in both countries simultaneously.

Cross-border planning must include identifying custodians that are genuinely cross-border capable, so your Canadian beneficiaries can make use of the ten-year withdrawal window rather than being forced into a taxable lump sum.

The Hidden Danger in Your Revocation Clause — Again

In Canadian law, beneficiary designations on RRSPs, RRIFs, and life insurance policies are considered testamentary dispositions. A general revocation clause in a new will — “I revoke all testamentary dispositions” — could be interpreted by a court or financial institution as inadvertently revoking your existing beneficiary designations on those accounts.

The fix is explicit protective language in your will: “I revoke all former Wills and testamentary dispositions, specifically excluding any beneficiary designations I have previously made on insurance policies or registered plans, unless I expressly refer to them in this Will.” Every cross-border will should contain this language.

A Note on BC Law: WESA and the Wills Variation Risk

For Americans living in British Columbia, WESA adds two important wrinkles worth understanding.

The good news first: under WESA Section 80, BC courts will generally recognize the formal validity of a will made in accordance with the laws of the jurisdiction where it was executed, the testator’s domicile, or the testator’s country of citizenship. A properly executed U.S. will can be recognized in BC. But this recognition addresses only the form of the will — it does not resolve how taxes are calculated or how assets are distributed, which still requires coordinated planning.

The risk: under WESA Section 60, a spouse or child can apply to BC’s Supreme Court to vary your will if they believe you failed to make adequate provision for their maintenance and support. This “moral obligation” doctrine can override your express testamentary wishes in ways that have no equivalent in most U.S. states. Americans in Canada need to be aware that their estate plan may face challenges on grounds that simply do not exist under American law.

The Administrative Reality: Forms, Deadlines, and Coordination

A well-structured cross-border estate plan is only as effective as the post-mortem administration that follows it. The filing burden for a U.S. citizen in Canada is significantly higher than for a domestic estate, and missed deadlines carry severe consequences.

These filings must be coordinated, not filed in isolation. The Treaty’s Article XXIX-B provides specific credit mechanisms to prevent both countries from fully taxing the same asset: Canada provides a credit against Canadian income tax for U.S. estate tax paid on U.S.-situated property, and the U.S. provides a credit for Canadian income tax paid on assets situated outside the United States. Getting these credits right requires careful sequencing — your Canadian and U.S. advisors need to work together from the moment of death, not after each jurisdiction has already filed independently. A poorly coordinated process can result in the estate paying in full in one country before having the documentation needed to claim relief in the other, creating a liquidity problem at the worst possible time for your family.

What Does a Well-Structured Cross-Border Estate Plan Look Like?

Every situation is different, but a well-coordinated plan for an American in British Columbia typically brings together the following elements:

1. Coordinated Dual Wills. A Canadian will for Canadian assets and a U.S. will for U.S. situs assets, linked by carefully drafted non-revocation and situs clauses. Each document is signed to satisfy the formal requirements of its jurisdiction.
2. Strategic Executor Selection. A BC-resident co-executor who is actively involved in managing the Canadian estate helps support Canadian estate residency for tax purposes, facilitates smoother dealings with local registries and institutions, and reduces the risk of court-ordered security. A separate U.S.-resident executor or professional trust company handles the American side concurrently.
3. Treaty-Aware Drafting. Provisions that explicitly authorize the executor to make the elections and file the returns needed to claim Treaty-based relief from double taxation under Article XXIX-B of the Canada-U.S. Tax Convention, including the marital credit for a surviving Canadian spouse and coordination of Canadian and U.S. tax credits.
4. Beneficiary Designation Review. A coordinated review of all registered accounts and retirement plans — RRSPs, RRIFs, TFSAs, IRAs, and 401(k)s — to minimize foreign trust reporting burdens, avoid inadvertent revocation, and identify cross-border-capable custodians where needed.
5. Ongoing Review. U.S. estate tax thresholds, Treaty provisions, and Canadian tax rules all change over time. A cross-border estate plan is not a one-time exercise — it should be reviewed whenever the law changes materially, your asset base shifts, or your personal circumstances evolve.

The Bottom Line

Your will is the foundation of your estate plan. But for Americans living in Canada, a document that works perfectly well in one country may be dangerously inadequate — or actively harmful — in the other.

The good news is that these problems are entirely solvable. With coordinated dual wills, the right executor structure, Treaty-aware drafting, and a thoughtful review of your registered accounts, you can protect your family from serial probate delays, double taxation, and years of administrative burden.

The key is getting the right team in place: a Canadian estate lawyer who understands cross-border issues, a U.S. tax specialist familiar with the Treaty, and a wealth manager who can bring the whole plan together.

At Beacon Hill, we work with Americans living in Canada every day. We understand the unique financial, tax, and legal landscape you navigate — and we work closely with your legal and tax advisors to ensure your estate plan and your investment strategy are fully aligned on both sides of the border.

This article is provided for general informational and educational purposes only and does not constitute legal, tax, or financial advice. Cross-border estate planning involves complex legal and tax considerations that are highly specific to individual circumstances. Nothing in this article should be construed as a recommendation to take any specific action. Readers should consult with a qualified Canadian estate lawyer, a U.S. tax specialist, and their financial advisor before making any estate planning decisions. Tax thresholds and legislative provisions referenced are subject to change.

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