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Cross-Border Tax (U.S.–Canada)

Ottawa to Salt Lake City: Defence Tech, Silicon Slopes, and Utah's Flat Tax

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

On this page

Hill Air Force Base, its contractor base, and Silicon Slopes' software companies recruit Ottawa's defence engineers and federal IT professionals. The move is a large tax cut: Ontario's combined top rate of about 53.5% becomes about 41.5% in Utah, with no city income tax and low property 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.
  • Utah's flat income tax, 4.5% after the 2025 cut. No city income tax.
  • A Canadian public service pension paid to a Utah resident is taxed federally with Canadian withholding capped at 15% under the treaty, and by Utah at the flat rate with a retirement credit available.
  • 13% HST becomes about 7.75% sales tax.
  • OHIP ends on permanent departure. Defence roles may require a green card, which sets the US residency start.

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. Utah taxes the pension at its flat rate, with a retirement tax credit available to older taxpayers. CPP and OAS are taxable only in the US.

Salt Lake City's side

Utah's flat income tax, 4.5% after the 2025 cut; no city income tax; sales tax about 7.75% in Salt Lake City; property tax among the lowest in the US, near 0.6% effective, with a 45% residential exemption on primary residences; no estate tax.

The RRSP in Utah

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

DND and CSE engineers to Hill Air Force Base's contractor base and Northrop Grumman's Utah operations, Ottawa cybersecurity staff to Silicon Slopes' security firms, federal IT professionals to Utah's software companies, and Ottawa program managers to Salt Lake City's corporate employers.

Worked example

A former DND engineer moves to Ogden on August 31 with $150,000 of unrealized gain in a non-registered account, $450,000 in an RRSP, and a Kanata 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 Utah deferral.
  • Ogden. Combined top rate about 41.5%. 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

Multiply line 9 by 4.5 percent (.045). — Utah State Tax Commission, Income Tax Rates, https://incometax.utah.gov/paying/tax-rates

Practitioner note

Ottawa-to-Utah clients heading to Hill Air Force Base contractors often need a green card for the role, and the card's issue date becomes the US residency start. We reconcile it with the Canadian departure date before the offer is signed.

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

Next step

Fairlight prepares the Ontario departure return, the residency-date reconciliation, and the first-year federal and Utah returns for Salt Lake City 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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