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Cross-Border Tax (U.S.–Canada)

Cross-Border Tax Help for Vancouver Residents Moving to the US: Three Vacancy Taxes, Founder Equity, and the Seattle Line

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

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Vancouver's US-bound residents carry a specific set of assets: concentrated tech equity, crypto, and real estate wealth built in one of the most expensive housing markets in North America. BC's combined top rate of about 53.5% sets the departure tax, and the province and the city have built a set of taxes aimed at non-resident and empty-home owners that catch anyone who leaves a Vancouver property behind. Fairlight works with Vancouver clients remotely from Miami, as most cross-border firms do; here is what the work involves.

Key takeaways

  • BC's combined top rate of about 53.5% sets the departure tax. On a $300,000 unrealized gain, roughly $80,000; on founder equity, far more.
  • A Vancouver home left empty by a non-resident faces BC's Speculation and Vacancy Tax, the City of Vancouver's Empty Homes Tax, and the federal Underused Housing Tax in the same year.
  • MSP ends on permanent departure; there is no premium to cancel, but the gap before US coverage is real.
  • Founder and early-employee shares in a private company are deemed sold at fair market value on departure; the valuation and the T1244 deferral are the file.
  • Vancouver-to-Seattle is the busiest corridor, and Washington's capital gains excise catches the equity sales that its no-income-tax reputation does not.

What a Vancouver file looks like

The equity. Vancouver's tech sector produces founders and early employees with concentrated private company shares. Those shares are deemed sold at fair market value on departure, and the departure date is a valuation date. Founders sometimes move in the window between a funding round and a liquidity event, when the value is defensible and the deemed gain is smaller than it will be later. The lifetime capital gains exemption can shelter up to $1.25 million of gain on qualified small business shares; security under Form T1244 defers the tax on shares that cannot be sold to pay it; and the Article XIII(7) election on the first US return steps up the US basis so the gain Canada taxed is not taxed again.

Crypto. Deemed sold on departure at fair market value. After the move, exchange accounts are on the FBAR and Form 8938.

The home. Excluded from departure tax; the principal residence exemption covers the years lived in. Keeping it is where Vancouver differs from every other Canadian city: BC's Speculation and Vacancy Tax applies in Metro Vancouver to homes that are not a principal residence or long-term rental, with higher rates for owners who pay most of their tax outside Canada; the City of Vancouver's Empty Homes Tax applies separately inside the city; and the federal Underused Housing Tax can apply to a non-resident, non-citizen owner. Rent it under NR6 and Section 216 from the first month, or sell in the departure year.

The day count. Vancouver tech workers often spend months in Seattle or the Bay Area before the formal move. The substantial presence test may have been met early, which changes the first US tax year and the FBAR start.

The destination. Seattle has no income tax but a 7% capital gains excise above an annual threshold ($278,000 for 2025) that catches RSU and founder share sales; the Bay Area taxes RRSP growth annually and gains at ordinary rates; Texas and Florida add nothing.

What to expect from a cross-border preparer

  • Both returns from one office: the departure-year T1 with the T1243, T1161, and T1244, and the first-year US return with the Article XIII(7) election, FBAR, and Form 8938.
  • A valuation plan for private shares before the departure date is set.
  • The home decision modelled with all three vacancy taxes.
  • An equity sale schedule mapped against Washington's excise threshold or California's ordinary rates.
  • Ongoing filings: Section 216 if the home is rented, NR4 reporting on RRSP withdrawals, Section 116 on a later sale, and the annual US return.

Where Vancouverites go

Seattle and the Bay Area for tech; Los Angeles for film and VFX; Austin, Denver, and Salt Lake City for tech with mountains; Miami and Florida for retirement and the Latin American market. Fairlight's corridor guides cover each Vancouver-to-city pair.

Worked example

A Vancouver founder with private company shares worth $2 million (ACB $200,000), $300,000 of unrealized gain in a brokerage account, $150,000 in crypto with a $50,000 cost base, $400,000 in an RRSP, and a Kitsilano house moves to Seattle on April 30.

  • Shares. $1.8 million gain, reduced by the LCGE where it qualifies; $900,000 taxable before the exemption; tax deferred with security under T1244; XIII(7) election steps up US basis.
  • Brokerage and crypto. $400,000 of gains, $200,000 taxable, roughly $107,000 of tax.
  • House. Sold in the departure year under the principal residence exemption. No vacancy taxes.
  • RRSP. No tax on departure; federal deferral; exempt from Washington's excise.
  • Seattle. Post-move share sales scheduled in tranches under the excise threshold.

Official sources

"The speculation and vacancy tax is an annual tax based on how owners use residential properties in areas in B.C. affected most by the current housing shortage crisis." — Government of British Columbia, Speculation and vacancy tax, https://www2.gov.bc.ca/gov/content/taxes/speculation-vacancy-tax

"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

Practitioner note

Vancouver files are valuation files. The departure date fixes the fair market value of private shares and crypto, and the difference between a defensible valuation in March and one in September can be six figures of departure tax. We get the valuation support in hand before the date is set, we file T1244 to defer the tax on anything that cannot be sold to pay it, and we make sure the condo is rented or sold before it accrues three vacancy taxes.

See also: Planning the move? Start with the Canada-to-US tax checklist and browse every corridor by city, province, and state.

Next step

Fairlight prepares the BC departure return with the valuation and T1244 deferral, the home decision, the first-year US return, and ongoing cross-border filings for Vancouver clients moving to the US. 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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