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Cross-Border Tax (U.S.–Canada)

Vancouver to Los Angeles: VFX, the Entertainment Corridor, and a Lateral Move on Tax

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

On this page

Vancouver and Los Angeles are the two poles of the North American film industry, and VFX artists, production crews, and studio staff move between them constantly. The tax picture is a lateral move: BC's combined top rate of about 53.5% becomes about 50.3% in California. What changes is the RRSP, which California taxes annually, and the Vancouver home, which faces three vacancy taxes if kept empty.

Key takeaways

  • BC's roughly 53.5% top rate sets the departure tax. On a $300,000 unrealized gain, about $80,000.
  • California's combined top rate is about 50.3%; capital gains at ordinary rates.
  • California does not follow the treaty on RRSPs, and the City of Los Angeles taxes freelancers' gross receipts.
  • BC's 12% combined GST and PST becomes 9.5% sales tax in most of Los Angeles County.
  • A Vancouver home kept empty faces three vacancy taxes. MSP ends on permanent departure.

The BC departure

Departure tax applies to non-registered investments, private company shares, crypto, and foreign property at fair market value on the departure date. BC 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. Realizing gains before departure at BC's half inclusion is often cheaper than carrying them into California. The Vancouver home is excluded, but kept empty it invites BC's Speculation and Vacancy Tax, Vancouver's Empty Homes Tax, and the federal Underused Housing Tax; rent it under NR6 and Section 216, or sell in the departure year.

Los Angeles's side

Graduated state rates to 12.3% plus a 1% surcharge above $1 million, for a combined federal and state top rate near 50.3%; capital gains taxed as ordinary income; 9.5% sales tax in most of Los Angeles County, up to 10.25% in some cities; Proposition 13 property tax at about 1.1% of purchase price with a 2% annual cap; no estate tax; aggressive residency audits; community property. The City of Los Angeles also levies a gross-receipts business tax that applies to freelancers and independent contractors from the first dollar of revenue earned in the city.

The RRSP in California

Federally deferred under Article XVIII of the treaty. California does not conform: the Franchise Tax Board taxes the interest, dividends, and realized gains inside the account each year. Before departure, restructure toward growth assets that produce little annual income, draw the account down while still a Canadian resident, or accept the annual inclusion and track California basis.

Freelancers

VFX and production work is often contract-based; Los Angeles's gross-receipts business tax applies from the first dollar earned in the city. A BC personal corporation left alive becomes a controlled foreign corporation; wind it up before departure.

Who makes this move

Vancouver VFX and animation artists to the Los Angeles studios, BC production crews to Los Angeles productions, Vancouver game developers to Los Angeles's gaming companies, and BC tech workers to the city's technology hubs.

Worked example

A Vancouver VFX supervisor moves to Los Angeles on July 1 with $250,000 of unrealized gain in a non-registered account, $400,000 in an RRSP producing about $12,000 a year of income, and a Vancouver condo sold in the departure year.

  • Departure tax. $250,000 gain, $125,000 taxable, at about 53.5%: roughly $67,000. Cheaper than California's ordinary-rate treatment later.
  • RRSP. Federally deferred. California taxes the $12,000 annual income; restructuring reduces it.
  • Condo. Sold as a resident under the principal residence exemption. No vacancy taxes.
  • Los Angeles. Combined top rate about 50.3%. Sales tax 12% becomes 9.5%.

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

California does not conform to federal tax treaty provisions; income excluded from federal income under a treaty may be taxable by California. — California Franchise Tax Board, Publication 1031, Guidelines for Determining Resident Status, https://www.ftb.ca.gov/forms/2025/2025-1031-publication.pdf

BC's Speculation and Vacancy Tax applies annually to residential property in designated taxable regions, with rates that depend on the owner's residency and tax status. — Government of British Columbia, Speculation and vacancy tax, https://www2.gov.bc.ca/gov/content/taxes/speculation-vacancy-tax

Practitioner note

Vancouver-to-Los Angeles clients often assume the move is tax-neutral and skip planning. The income tax is close to neutral; the RRSP position, the pre-departure gain realization, the Los Angeles business tax, and the Vancouver condo are not.

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

Next step

Fairlight prepares the BC departure return, the RRSP restructuring, the property decision, and the first-year federal and California returns for Los Angeles 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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