Toronto to Atlanta: Tech, Film, and Georgia's Flat Tax With No City Layer
Reviewed by the Fairlight Accounting cross-border tax team — U.S. & Canadian Tax Desks
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Toronto and Atlanta are both film production centres, both fintech hubs, and both cities where consulting and technology firms cluster. The move trades Ontario's combined top rate of about 53.5% for about 42% in Georgia, with no municipal income tax. The planning is on the Ontario side: the departure tax, the Toronto home, and the equity.
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.
- Georgia's flat income tax is 4.99% for 2026, down from 5.19% in 2025. No city income tax.
- Georgia follows the treaty's RRSP deferral.
- 13% HST becomes 8.9% sales tax in the City of Atlanta, 7% to 7.75% in the suburbs.
- OHIP ends on permanent departure. Keeping the Toronto home means NR6, Section 216, and the Vacant Home Tax if empty.
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 pensions are excluded. Report on Form T1243, list holdings on Form T1161 if the total exceeds $25,000, and post security under Form T1244 for illiquid assets. The Toronto home: sell it under the principal residence exemption, rent it under NR6 and Section 216, or face Toronto's Vacant Home Tax if it sits empty.
Atlanta's side
Flat state income tax stepping down annually; no city income tax; 8.9% sales tax in the City of Atlanta; property tax near 1% effective with county homestead exemptions; no estate tax.
The RRSP in Georgia
Federally deferred under Article XVIII of the treaty and deferred for Georgia 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 Georgia's flat rate.
Equity
RSUs vesting after the move are split by working days between Canada and the US; both payrolls may withhold on the full amount, and the excess is recoverable on the first-year returns.
Who makes this move
Toronto tech workers to Atlanta's software and fintech employers, consulting staff to the Atlanta offices of the large firms, Toronto film and television crews to the Georgia production industry, and Bay Street finance professionals to Atlanta's corporate treasury and banking roles.
Worked example
A Toronto fintech product manager moves to Atlanta on May 31 with $220,000 of unrealized gain in a non-registered account, $500,000 in an RRSP, RSUs vesting in October, 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.
- RSUs. October vest split by working days.
- RRSP. No tax on departure; federal and Georgia deferral.
- Atlanta. Combined top rate about 42%. HST 13% becomes sales tax 8.9%.
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
The Georgia income tax rate has been reduced to a flat rate of 4.99%. — Georgia Department of Revenue, Important Tax Updates, https://dor.georgia.gov/taxes/important-tax-updates
There are 5 Ontario income tax brackets and 5 corresponding tax rates. — Government of Ontario, Personal income tax, https://data.ontario.ca/dataset/personal-income-tax-rates-and-credits
Practitioner note
Toronto-to-Atlanta files are among the simplest US-side files we see, and the errors are all on the Ontario side: an NR6 filed late on a rented condo, a TFSA left open into the first US year, a departure date chosen without checking the unrealized gain. All three are cheaper to fix before the move.
See also: Weighing Florida instead? See the Canada-to-Florida guide, or the same city's Toronto to Miami guide.
Next step
Fairlight prepares the Ontario departure return, the property filings, and the first-year federal and Georgia returns. See cross-border pricing or book a call.
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