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Cross-Border Tax (U.S.–Canada)

Calgary to Orlando: Simulation, Defence Engineering, and Alberta's Lightest Exit

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

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Orlando is not on most Calgarians' radar until a recruiter calls from the simulation and training corridor around the University of Central Florida. Lockheed Martin, the US military's simulation commands, and a dense cluster of engineering contractors sit within a few miles of each other in east Orlando, and the skills they want (systems engineering, project management, controls) are the skills Calgary's energy sector has been producing for decades. The tax side is the easiest in Canada: Alberta's combined top rate of about 48% is the lowest of any province, and Florida charges no state income tax.

Key takeaways

  • Departure tax is measured at Alberta's roughly 48% top rate. On a $300,000 unrealized gain, expect about $72,000.
  • Orlando has no city income tax; Florida has no state income tax. US tax is federal only.
  • Sales tax rises from Alberta's 5% GST to 6.5% in Orange County.
  • Alberta Health Care Insurance Plan coverage ends on permanent departure. Employer plans in the defence sector usually start on day one; confirm the dates line up.
  • Defence contractor work often requires US citizenship or a green card, which changes the immigration path and the tax residency start date.

Leaving Alberta

The deemed disposition on emigration catches non-registered investments, private company shares, crypto, and foreign property, valued at fair market value on the departure date. Alberta real estate, RRSPs, TFSAs, and pensions are excluded. You report the gain on Form T1243, list holdings on Form T1161 if their total exceeds $25,000, and can post security under Form T1244 to defer the tax on illiquid assets.

Alberta's 15% top provincial bracket on top of the 33% federal bracket gives about 48%. With half of a capital gain taxable, the effective exit rate on gains at the top bracket is roughly 24 cents on the dollar. No other province is lower.

Engineers leaving Calgary often hold shares in a professional or consulting corporation. Those shares are deemed sold, the corporation loses CCPC status when its controlling shareholder leaves, and on the US side it becomes a controlled foreign corporation with annual Form 5471 filings. Decide whether to wind it up before departure, while the capital dividend account can still be paid tax-free to a Canadian resident.

Orlando's side

Florida levies no personal income tax and no estate tax. Orlando levies no municipal income tax. What you pay:

  • Sales tax. 6% state plus Orange County's 0.5% surtax, 6.5% total. Slightly lower than Miami-Dade's 7%.
  • Property tax. Higher than Calgary on a like-for-like home. A newly purchased Orange or Seminole County home runs an effective rate in the high 1% range until homestead applies.
  • Homestead. Own and occupy as your permanent residence on January 1 and apply by March 1 for up to $50,000 off assessed value and a 3% annual cap on assessment increases.
  • Documentary stamp tax. 0.7% of the purchase price on the deed.

Equity, clearances, and the residency start

Defence contractors pay in salary plus equity, and many roles require a security clearance that in turn requires US citizenship or permanent residence. Two consequences. First, the immigration path (often a green card through employer sponsorship) makes US tax residency start on the green card date if the substantial presence test has not already been met. Second, equity that vests after the move is split between Canada and the US by working days over the vesting period, so tell payroll the departure date in writing.

The RRSP in Orlando

Untouched on departure. Tax-deferred in the US under Article XVIII of the treaty, with no Florida state layer to break the deferral. Withdrawals face 25% Canadian withholding on lump sums, 15% on periodic RRIF payments within the treaty limit, with a US foreign tax credit.

Worked example

A Calgary systems engineer takes a role at a simulation contractor in Orlando, leaving Alberta on August 31 with $200,000 of unrealized gain in a brokerage account, $450,000 in an RRSP, a consulting corporation with $150,000 of retained earnings, and a Calgary home sold in the departure year.

  • Departure tax. $200,000 gain, $100,000 taxable, at about 48%: roughly $48,000.
  • Corporation. Pay the capital dividend account and wind up before August 31, or accept Form 5471 filings in the US.
  • Home. Sold as a resident under the principal residence exemption.
  • RRSP. No tax on departure; periodic withdrawals later at 15%.
  • Orlando. No state or city income tax. GST 5% becomes sales tax 6.5%.

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

"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

Florida's discretionary sales surtax rates are set by county and published annually by the Florida Department of Revenue. — Florida Department of Revenue, Discretionary Sales Surtax, https://floridarevenue.com/taxes/taxesfees/Pages/discretionary.aspx

Practitioner note

Orlando files have one wrinkle the Miami files rarely do: a green card through a defence employer. When the green card date falls in a year before the substantial presence test would have been met, that date becomes the US residency start, and the Canadian departure date should be coordinated with it rather than set independently. We line the two dates up before the client accepts the offer.

See also: Calgary to Miami and Calgary to Tampa.

Next step

Fairlight prepares the Alberta departure return, the corporate wind-up, and the first-year US return for Central Florida clients. 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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