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Cross-Border Tax (U.S.–Canada)

Moving From Canada to the U.S.: Your First U.S. Tax Year

The starting date, the move-year return, the basis election, and what to close or report

Reviewed by the Fairlight Accounting cross-border tax team — U.S. & Canadian Tax Desks

A Canadian who moves to the United States becomes a U.S. tax resident on a starting date set by the green card or the substantial presence test. The move year is usually a dual-status return, the treaty basis election protects departure-taxed gains, and some Canadian accounts are best closed before leaving.

On this page
  1. The first-year checklist
  2. State taxes
  3. The Canadian side
  4. Frequently asked questions
  5. Related guides
  6. Official sources
  7. Next step

The first-year checklist

ItemWhat to do
Residency starting dateFirst day present as a green card holder, or first day of presence in the year the substantial presence test is met (up to 10 days with a closer connection to Canada can be disregarded) (the substantial presence guide)
Move-year returnDual-status, or a full-year joint return with the nonresident spouse election (the dual-status and nonresident spouse guides)
Basis electionArticle XIII(7) on the first U.S. return for departure-taxed property (the departure tax guide), disclosed on Form 8833
TFSAClose before the move — not recognized by the U.S. (the TFSA vs Roth guide)
Canadian mutual funds and ETFsPFICs — sell before the move or plan elections (the PFIC guide)
RRSP and RRIFKeep — deferred automatically under the treaty; stop contributing
Canadian corporationPlan before leaving — the CFC rules apply from the starting date (the kept-Canadian-corporation guide)
FBAR and Form 8938Report Canadian accounts from the first resident year

State taxes

Florida has no personal income tax, and neither do Alaska, Nevada, New Hampshire, South Dakota, Tennessee, Texas, or Wyoming (Washington taxes only certain capital gains); the other states tax residents under their own residency rules, usually with a part-year resident return for the move year.

The Canadian side

The final Canadian return with the departure date, the departure tax computations, and Form NR73 if residency is uncertain (the NR73 guide); the Canada child benefit and the Canada Groceries and Essentials Benefit (the GST/HST credit, renamed in July 2026) end (the Canada child benefit guide).

Frequently asked questions

When do I become a U.S. tax resident?

On the first day you're in the United States as a green card holder, or the first day of presence in the year you meet the substantial presence test.

Will the U.S. tax gains on my Canadian investments from before I moved?

Not if you make the treaty's basis election for property Canada taxed on departure.

Should I close my TFSA before moving?

Generally yes — the United States doesn't recognize it.

Can I keep my RRSP?

Yes — its growth stays tax-deferred in the United States under the treaty.

Official sources

The IRS explains: “If you meet the substantial presence test for a calendar year, your residency starting date is generally the first day you are present in the United States during that calendar year.” — Internal Revenue Service, Publication 519 (2025), U.S. Tax Guide for Aliens, https://www.irs.gov/publications/p519

The CRA explains: “If you ceased to be a resident of Canada in the year, you were deemed to have disposed of certain types of property at their fair market value (FMV) when you left Canada and to have immediately reacquired them for the same amount. This is called a deemed disposition.” — Canada Revenue Agency, Dispositions of property for emigrants of Canada, https://www.canada.ca/en/revenue-agency/services/tax/international-non-residents/individuals-leaving-entering-canada-non-residents/dispositions-property.html

Next step

Fairlight Accounting is a cross-border accounting and tax practice with a U.S. Tax Desk and a Canadian Tax Desk. Our U.S. Tax Desk and Canadian Tax Desk handle Canada-to-U.S. move planning — residency starting dates, move-year returns, basis elections, pre-move account restructuring, and the Canadian departure return. See pricing or book a call.

Cross-border taxes, handled in one place

U.S. and Canadian filings prepared together by our U.S. and Canadian Tax Desks.

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