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Cross-Border Tax (U.S.–Canada)

Moving from Canada to Utah: Silicon Slopes, a Flat Tax, and Low Property Tax

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

On this page

Salt Lake City and the Silicon Slopes corridor south of it have become one of the fastest-growing tech markets in the US, and Utah's finance, aerospace, and outdoor-industry employers recruit Canadians as well. The tax picture is a flat income tax cut in most recent years, no local income taxes, low sales and property taxes, and no estate tax.

Key takeaways

  • Utah's flat income tax is 4.5% after the 2025 cut. No local income taxes.
  • Utah starts from federal AGI, so the treaty's RRSP deferral flows through.
  • Sales tax is about 7.75% in Salt Lake City, 7.25% in Utah County.
  • Property tax is among the lowest in the US, near 0.6% effective, with a 45% residential exemption on primary residences.
  • No estate tax. Utah offers a retirement tax credit for older taxpayers.

The Canadian departure

Departure tax applies to non-registered investments, private company shares, crypto, and foreign property at fair market value on the day you leave. Canadian real estate, RRSPs, TFSAs, and pensions are excluded. Report on Form T1243, list holdings on Form T1161 if the total exceeds $25,000, and post security under Form T1244 to defer tax on illiquid assets. The rate is your province's: on a $300,000 unrealized gain, roughly $72,000 from Alberta and $80,000 from Ontario, Quebec, or BC. Provincial health coverage ends around your departure date; confirm the exact date with your plan and arrange US coverage to start the same month.

US federal side

Dual-status return in the arrival year, FBAR on Canadian accounts above $10,000 aggregate, Form 8938 above thresholds, and the RRSP treaty deferral federally. The TFSA loses its tax-free status the day you become a US person; close it before crossing. Equity compensation vesting after the move is split by working days between Canada and the US.

Utah's side

Flat income tax of 4.5% after the 2025 reduction; no local income taxes; 4.85% state sales tax plus local, about 7.75% in Salt Lake City and 7.25% in Lehi and Provo; property tax near 0.6% effective with a 45% exemption on primary residences; no estate tax. Utah starts from federal AGI and offers a retirement tax credit for taxpayers born before 1953 and a Social Security credit for others.

The RRSP

Federally deferred under Article XVIII of the treaty and deferred for Utah because the state starts from federal AGI. Withdrawals face 25% Canadian withholding on lump sums, 15% on periodic RRIF payments within the treaty limit, a US foreign tax credit federally, and Utah's flat rate.

Who makes this move

Canadian software engineers to Silicon Slopes' tech companies, Bay Street finance staff to Goldman Sachs and Salt Lake City's financial services sector, Canadian defence and aerospace engineers to Hill Air Force Base's contractor base and Northrop Grumman, Canadian outdoor-industry professionals to Utah's recreation brands and ski resorts, and Canadian healthcare professionals to Intermountain Health.

Worked example

A Toronto software engineer moves to Lehi on June 30 with $220,000 of unrealized gain in a non-registered account, $450,000 in an RRSP, and a Toronto condo sold in the departure year.

  • Departure tax. $220,000 gain, $110,000 taxable, at about 53.5%: roughly $59,000.
  • Condo. Sold as a resident under the principal residence exemption.
  • RRSP. No tax on departure; federal and Utah deferral.
  • Lehi. Combined top rate about 41.5%. HST 13% becomes sales tax 7.25%. Property tax on a $750,000 home around $3,700.

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

"January 1, 2025 – current: 4.5% or .045; January 1, 2024 – December 31, 2024: 4.55% or .0455." — Utah State Tax Commission, Income Tax Rates, https://incometax.utah.gov/paying/tax-rates

"You will be considered a United States resident for tax purposes if you meet the substantial presence test for the calendar year. To meet this test, you must be physically present in the United States (U.S.) on at least: 31 days during the current year, and 183 days during the 3-year period that includes the current year and the 2 years immediately before that." — Internal Revenue Service, Substantial Presence Test, https://www.irs.gov/individuals/international-taxpayers/substantial-presence-test

Practitioner note

Utah's flat rate has been cut several years running, and relocation packages are often built on last year's number. We confirm the current rate before modelling the move. Hill Air Force Base contractor roles often require a green card, which sets the US residency start.

Corridor guides

See also: Weighing Florida instead? See the Canada-to-Florida guide. Browse every corridor by city, province, and state.

Next step

Fairlight prepares the Canadian departure return, the first-year federal and state returns, and ongoing cross-border filings. 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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