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Cross-Border Tax (U.S.–Canada)

Vancouver to Philadelphia: Biotech, Pennsylvania's Flat 3.07%, and the City Wage Tax

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

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Philadelphia's life sciences corridor and its healthcare systems recruit Vancouver's biotech researchers and clinicians, and its fintech and enterprise employers recruit Vancouver's software engineers. The move is a large tax cut: BC's combined top rate of about 53.5% becomes about 43.8% inside Philadelphia or about 41% in the suburbs. The Vancouver home is the planning item.

Key takeaways

  • BC's roughly 53.5% top rate sets the departure tax. On a $300,000 unrealized gain, about $80,000.
  • Pennsylvania's flat 3.07% plus Philadelphia's roughly 3.74% resident wage tax; suburbs charge about 1%.
  • Pennsylvania exempts most retirement income after retirement age.
  • BC's 12% combined GST and PST becomes 8% sales tax in Philadelphia, 6% in the suburbs.
  • 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. 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. MSP ends on permanent departure.

Philadelphia's side

Pennsylvania's flat 3.07% state income tax; Philadelphia's Wage Tax of about 3.74% on residents (about 3.43% on non-residents who work in the city), which most suburbs replace with a 1% local earned income tax; 8% sales tax in Philadelphia (6% state plus 2% city), 6% in most suburbs; property tax near 1.4% effective; no estate tax, but Pennsylvania's inheritance tax applies at 4.5% to lineal heirs, 12% to siblings, and 15% to others, with a spousal exemption.

The RRSP in Pennsylvania

Federally deferred under Article XVIII of the treaty. Pennsylvania taxes eight classes of income rather than starting from federal AGI, and it does not tax the undistributed earnings of retirement plans, which supports deferral. Pennsylvania also exempts most retirement income received after retirement age, which can cover RRIF withdrawals; document the position in the first-year file. Canadian withholding is 25% on lump sums, 15% on periodic RRIF payments within the treaty limit, with a US foreign tax credit federally.

Who makes this move

Vancouver biotech researchers to the Philadelphia life sciences corridor, BC clinicians to Penn Medicine and the city's hospital systems, Vancouver software engineers to Comcast and Philadelphia's fintech employers, and BC mining finance professionals to the region's banks.

Worked example

A Vancouver biotech scientist moves to the Philadelphia suburbs on May 31 with $200,000 of unrealized gain in a non-registered account, $350,000 in an RRSP, and a Vancouver condo sold in the departure year.

  • Departure tax. $200,000 gain, $100,000 taxable, at about 53.5%: roughly $53,500.
  • Condo. Sold as a resident under the principal residence exemption. No vacancy taxes.
  • RRSP. Federally deferred; Pennsylvania position documented.
  • Suburbs. State 3.07% plus 1% local. Combined top rate about 41%. Sales tax 12% becomes 6%.

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

Pennsylvania personal income tax is levied at the rate of 3.07 percent. — Pennsylvania Department of Revenue, Personal Income Tax, https://www.pa.gov/en/agencies/revenue/resources/tax-types-and-information/personal-income-tax.html

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-Philadelphia movers trade a low property tax for a moderate one and a 12% sales tax for a 6% one. The condo left behind is the mistake to avoid: sell or rent it in the departure year.

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 property decision, and the first-year federal, Pennsylvania, and local returns for Philadelphia 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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