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Cross-Border Tax (U.S.–Canada)

Moving from Canada to Wyoming: No Income Tax, No Estate Tax, and the Energy and Ranching Corridor

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

On this page

Wyoming is a no-income-tax state with no corporate income tax, no estate tax, low sales tax, and low property tax. Alberta and Saskatchewan energy workers move there for the coal, gas, and trona industries; ranchers and agricultural professionals for the land; and a wealthier stream for Jackson Hole. The US side of the move is nearly free of state tax; the Canadian side carries the departure tax.

Key takeaways

  • Wyoming has no personal income tax, no corporate income tax, and no estate or inheritance tax.
  • Sales tax is 4% state plus local, 5% to 6% in most counties.
  • Property tax is low, near 0.6% effective.
  • The RRSP is untouched: no state income tax means no state layer.
  • Wyoming's trust laws make it a common situs for family trusts.

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.

Wyoming's side

No personal income tax; no corporate income tax; no estate or inheritance tax; 4% state sales tax plus local, 5% to 6% in most counties; property tax near 0.6% effective with residential property assessed at 9.5% of value. Wyoming's revenue comes from mineral severance taxes and federal mineral royalties. Its trust laws (no state income tax on trust income, 1,000-year trusts, strong asset protection) make it a common situs for US and cross-border family trusts.

The RRSP

Untouched on departure, federally deferred under Article XVIII of the treaty, with no Wyoming layer. 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

Alberta and Saskatchewan energy workers to Wyoming's coal, natural gas, and trona operations, Canadian ranchers and agricultural professionals to the state's cattle industry, Canadian outdoor-industry and hospitality staff to Jackson Hole, Canadian family offices using Wyoming trusts, and Canadian academics to the University of Wyoming.

Worked example

A Calgary mining engineer moves to Gillette on June 30 with $180,000 of unrealized gain in a non-registered account, $400,000 in an RRSP, and a Calgary home sold in the departure year.

  • Departure tax. $180,000 gain, $90,000 taxable, at about 48%: roughly $43,000.
  • Home. Sold as a resident under the principal residence exemption.
  • RRSP. No tax on departure; no state layer on withdrawals.
  • Gillette. No state income tax. GST 5% becomes sales tax 5%. Property tax on a $400,000 home around $2,400.

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

"To fairly and efficiently collect all sales, use, lodging, cigarette and estate tax owed the State of Wyoming and its political subdivisions." — Wyoming Department of Revenue, Our Mission (Excise Tax Division), https://revenue.wyo.gov/our-mission

"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

Wyoming is one of the cleanest US destinations for an Alberta mover: no state tax of any kind on income or estates, a sales tax equal to the GST, and low property tax. The departure tax on the Canadian side and the Calgary corporation are the whole file.

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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