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Cross-Border Tax (U.S.–Canada)

Ottawa to Raleigh: Government Skills, the Triangle, and North Carolina's Falling Flat Tax

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

On this page

Research Triangle Park's software, pharma, and research employers recruit Ottawa's federal IT professionals, health scientists, and defence engineers. The move is a large tax cut: Ontario's combined top rate of about 53.5% becomes about 41% in North Carolina, with no city income tax.

Key takeaways

  • Ontario's roughly 53.5% top rate, including the provincial surtax, sets the departure tax. On a $300,000 unrealized gain, about $80,000.
  • North Carolina's flat income tax is 3.99% for 2026 and still stepping down. No city income tax.
  • A Canadian public service pension paid to a North Carolina resident is taxed federally with Canadian withholding capped at 15% under the treaty, and by North Carolina at the flat rate.
  • 13% HST becomes 7.25% sales tax.
  • OHIP ends on permanent departure.

The Ontario departure

Departure tax applies to non-registered investments, private company shares, crypto, and foreign property at fair market value on the departure date. Ontario real estate, RRSPs, TFSAs, and registered pensions are excluded. Report on Form T1243, list holdings on Form T1161 if the total exceeds $25,000. The Ontario surtax ends on departure. OHIP ends on permanent departure.

The federal pension

Under Article XVIII of the treaty, Canadian tax on periodic pension payments to a US resident is capped at 15%; file NR301 before the first post-departure payment. The US taxes the pension federally with a foreign tax credit. North Carolina taxes the pension at its flat rate. CPP and OAS are taxable only in the US.

Raleigh's side

North Carolina's flat income tax is 3.99% for 2026 under the state's step-down schedule; no city income tax; 7.25% sales tax in Wake County; property tax near 0.8% effective; no estate tax.

The RRSP in North Carolina

Federally deferred under Article XVIII of the treaty and deferred for North Carolina 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 North Carolina's flat rate.

Who makes this move

Ottawa federal IT and cybersecurity staff to Research Triangle Park's software employers, Health Canada scientists to the Triangle's pharma and biotech firms, DND engineers to the region's defence contractors, and Ottawa researchers to Duke, UNC, and NC State.

Worked example

A federal IT manager moves to Raleigh on August 31 with $150,000 of unrealized gain in a non-registered account, $450,000 in an RRSP, and a Barrhaven home sold in the departure year.

  • Departure tax. $150,000 gain, $75,000 taxable, at about 53.5%: roughly $40,000.
  • Home. Sold as a resident under the principal residence exemption.
  • RRSP. No tax on departure; federal and North Carolina deferral.
  • Raleigh. Combined top rate about 41%. HST 13% becomes sales tax 7.25%.

Official sources

"Pensions may also be taxed in the Contracting State in which they arise and according to the laws of that State; but if a resident of the other Contracting State is the beneficial owner of a periodic pension payment, the tax so charged shall not exceed 15 per cent of the gross amount of such payment." — Canada-United States Tax Convention, Article XVIII(2)(a), https://www.canada.ca/en/department-finance/programs/tax-policy/tax-treaties/country/united-states-america-convention-consolidated-1980-1983-1984-1995-1997.html

"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

For Taxable Years after 2025, the North Carolina individual income tax rate is 3.99% (0.0399). — North Carolina Department of Revenue, Tax Rate Schedules, https://www.ncdor.gov/taxes-forms/individual-income-tax/tax-rate-schedules

Practitioner note

Ottawa-to-Raleigh files are among the simplest we prepare: no city tax, a flat state rate, and a state that follows the treaty on the RRSP. The NR301 on a federal pension is the one form that gets missed.

See also: Weighing Florida instead? See the Canada-to-Florida guide, or the same city's Ottawa to Miami guide. Comparing the Carolinas? See Ottawa to Charlotte.

Next step

Fairlight prepares the Ontario departure return, the pension withholding paperwork, and the first-year federal and North Carolina returns for Raleigh 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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