Calgary to Miami: Energy Finance, Departure Tax, and Alberta's Cleanest Exit
Reviewed by the Fairlight Accounting cross-border tax team — U.S. & Canadian Tax Desks
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Calgary and Miami are both finance cities built on something physical: oil and gas in one case, Latin American trade in the other. The corridor between them runs on energy traders, commodities finance, and executives following their firms into Brickell's growing trading and family-office cluster. On the tax side it is the cleanest city-to-Miami move available, because Alberta's top combined rate of about 48% is the lowest in Canada and Florida adds nothing on the other side.
Key takeaways
- Alberta's roughly 48% top rate sets the departure tax. On a $300,000 unrealized gain, expect about $72,000, the lowest of any Canadian city corridor into Miami.
- Miami has no city income tax and Florida has no state income tax. Your US tax is federal only.
- Sales tax goes up: 5% GST in Calgary to 7% in Miami-Dade.
- Calgary professional corporations and holding companies need a plan before departure, not after.
- Equity compensation from an energy employer is sourced by where you worked when it was earned, so a mid-year move splits it across two countries.
The Calgary departure
Departure tax is a deemed sale of non-registered investments, private company shares, crypto, and foreign property at fair market value on the day you leave. Alberta real estate, RRSPs, TFSAs, and pensions are excluded. Report on Form T1243, list property on Form T1161 if the total exceeds $25,000, and consider deferral under Form T1244 for illiquid holdings.
The Calgary-specific complication is corporate. A large share of the people making this move own a professional corporation, a consulting company, or a holding company sitting under one. The shares are deemed sold on departure. The corporation loses CCPC status when its controlling shareholder ceases to be a Canadian resident, and on the US side it becomes a controlled foreign corporation with Form 5471 filings and potential GILTI inclusions. Winding up before departure, paying out the capital dividend account while you are still a Canadian resident, or keeping the corporation with a US-side plan are the three options, and they need months, not weeks.
AHCIP coverage ends when you leave Alberta permanently. Confirm the end date and start US coverage the same month.
Equity and deferred compensation
Energy sector pay often includes RSUs, stock options, and deferred bonuses. Under the treaty, employment income is sourced to where the work was performed. A grant that vests after the move is split between Canada and the US by working days in each country over the vesting period. Both payroll systems may withhold on the full amount; the excess is recoverable, but only if the first-year returns are done correctly. Tell your employer's payroll team the departure date in writing.
Miami's side
Florida has no personal income tax and no estate tax, and Miami levies no municipal income tax. What you pay instead:
- Sales tax. 7% in Miami-Dade.
- Property tax. Higher than Calgary on a like-for-like home. Budget an effective rate in the high 1% range until homestead applies.
- Homestead. Own and occupy as your permanent residence on January 1, apply by March 1, for up to $50,000 off assessed value and a 3% annual assessment cap.
- Documentary stamp tax. 0.6% of the price on a single-family deed in Miami-Dade.
The RRSP
Untouched on departure. Tax-deferred in the US under Article XVIII of the treaty, with no Florida state layer to interfere. Withdrawals face 25% Canadian withholding on lump sums, 15% on periodic RRIF payments within the treaty limit, with a US foreign tax credit.
Who makes this move
Energy trading desks and commodities finance firms with Miami offices, Latin American energy companies with regional headquarters in Brickell and Coral Gables, and Calgary executives following private capital into South Florida's family-office scene. A smaller stream is early retirees cashing out of the energy sector and choosing Miami over Phoenix.
Worked example
A Calgary energy finance professional leaves on May 31 with $300,000 of unrealized gain in a brokerage account, $700,000 in an RRSP, a holding company with $400,000 of retained investments, and RSUs vesting in December.
- Departure tax. $300,000 gain, $150,000 taxable, at about 48%: roughly $72,000. The holding company shares are also deemed sold; the gain depends on their adjusted cost base.
- Holding company. Wind up before departure, or accept CFC status and Form 5471 in the US. Decide before May 31.
- RSUs. December vest split by U.S. and Canadian working days over the vesting period.
- RRSP. No tax on departure; periodic withdrawals later at 15%.
- Miami. No state or city income tax on any of it.
Official sources
"When you leave Canada, you are considered to have sold certain types of property (even if you have not sold them) at their fair market value (FMV) and to have immediately reacquired them for the same amount. This is called a deemed disposition and you may have to report a capital gain (also known as departure tax)." — Canada Revenue Agency, Leaving Canada (emigrants), https://www.canada.ca/en/revenue-agency/services/tax/international-non-residents/individuals-leaving-entering-canada-non-residents/leaving-canada-emigrants.html
Form 5471 is required of certain US persons who are officers, directors, or shareholders in certain foreign corporations. — Internal Revenue Service, About Form 5471, https://www.irs.gov/forms-pubs/about-form-5471
"No tax upon estates or inheritances or upon the income of natural persons who are residents or citizens of the state shall be levied by the state, or under its authority." — Florida Constitution, Article VII, Section 5(a), http://www.leg.state.fl.us/statutes/index.cfm?submenu=3#A7S05
Practitioner note
The Calgary file is the one where the corporation, not the portfolio, drives the timeline. A holding company with retained investment income left alive after departure produces a Form 5471 every year, a possible GILTI inclusion, and a shareholder who cannot take the capital dividend account tax-free anymore. We start the corporate analysis before we set the departure date, because the answer sometimes moves the date.
Next step
Fairlight prepares the Alberta departure return, the corporate wind-up or CFC filings, and the first-year US return. See cross-border 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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