California residents with Canadian RRSP – Need tax help!

10 July 24
Cross Border Tax

Question

Hi Phil,

My wife and I (61 and 62, respectively) are California residents and we each have an RRSP in Quebec.

I’d like to access this Canadian money in a tax efficient manner.

My RRSP has about 100k CAD and my wife’s has about 55k CAD. We file jointly in the US and do not file in Canada. My effective federal tax rate for 2024 will be below 10%.

Happy to pay for the service but I’d prefer to do it by giving you our business for 2024 US tax prep.

Would you please advise?

Regards,

XXXXX

Answer

Hi XXXXXX

I’ve moved over to the wealth management side of the industry; however, I should be able to give you some general guidance on your situation.

Just a note that my response is for informational purposes only and you’ll want to get a proper legal tax opinion before making any changes.

This will be dependent on your tax situation and current US tax rates, however in most cases it will be much more efficient to convert the RRSP to a RRIF to gain access to the 15% Canadian withholding rate under the Canada US tax treaty.

If you withdraw funds from the RRSP before converted to a RRIF the withholding rate under the treaty will be 25%. In both cases you’ll get credit in the US for Canadian taxes paid, however if your US rate is lower than 25%, you’ll end up paying the full 25% on the RRSP withdrawal regardless.

In some cases, it makes sense to try and calculate the cost basis in the RRSP for US purposes to reduce the taxable amount of the RRSP/RRIF withdrawal for US purposes, but that is certainly lots of work.

For example if you assumed your US tax rate is around 10% it does seem like converting the RRSP to a RRIF is the most efficient way of withdrawing the funds from the registered account. You may be able to file a s.217 Canadian income tax return, however that can get expensive, and it will be unlikely to get below 15%.

Hope that helps and please feel free to take advantage of our complementary cross-border investment consultation to review your investments and tax positions and to see if we can add value to the process.

Cheers

Phil

Phil Hogan, CPA, CA, CPA (Colorado)

Phil Hogan is a Canadian and US CPA working with clients throughout Canada and the US. Phil advises on cross border tax and financial planning matters. Phil can be reached at phil@beaconhillwm.ca or via telephone at 250-661-9417. You can also read more about Phil at www.Beaconhillwm.ca/team/about-phil/

This commentary reflects the personal opinions, viewpoints and analyses of the Beacon Hill Wealth Management Ltd. partner providing such comments, and should not be regarded as a description of advisory services provided by Beacon Hill Wealth Management Ltd. or performance returns of any Beacon Hill Wealth Management Ltd. client. The views reflected in the commentary are subject to change at any time without notice. Nothing in this commentary constitutes investment advice, performance data or any recommendation that any particular security, portfolio of securities, transaction or investment strategy is suitable for any specific person. Any mention of a particular security and related performance data is not a recommendation to buy or sell that security. Beacon Hill Wealth Management Ltd. manages its clients’ accounts using a variety of investment techniques and strategies, which are not necessarily discussed in the commentary. Investments in securities involve the risk of loss. Past performance is no guarantee of future results. Any discussion about taxation is for educational purposes only and should not be viewed as professional advice. Consult your tax professional for tax advice on your particular situation.

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