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Cross-Border Tax (U.S.–Canada)

Vancouver to Pittsburgh: Tech, Robotics, and the Property Tax Flip

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

On this page

Vancouver's software and robotics engineers have a market in Pittsburgh's AI and autonomous vehicle companies, and the move is a large tax cut: BC's combined top rate of about 53.5% becomes about 43% inside Pittsburgh or about 41% in the suburbs. The property tax flip (low in Vancouver, high in Allegheny County) and the Vancouver home left behind are the planning items.

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 a 3% local earned income tax on Pittsburgh residents; suburbs charge about 1%.
  • Pennsylvania exempts most retirement income after retirement age.
  • BC's 12% combined GST and PST becomes 7% sales tax.
  • 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.

Pittsburgh's side

Pennsylvania's flat 3.07% state income tax; a 3% local earned income tax on Pittsburgh residents (1% city plus 2% school district), with most suburbs charging 1%; 7% sales tax in Allegheny County; property tax among the higher effective rates in the US, near 2% in Allegheny County after recent reassessments; 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 robotics and autonomous vehicle engineers to Pittsburgh's AV companies, BC software engineers to the city's AI and tech employers, Vancouver clean-tech professionals to Pittsburgh's energy technology firms, and UBC researchers to Carnegie Mellon and Pitt.

Worked example

A Vancouver robotics engineer moves to Pittsburgh on July 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.
  • Pittsburgh. State 3.07% plus 3% local. Combined top rate about 43%. Sales tax 12% becomes 7%.

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

The city earned income tax is levied at a rate of 1% on the wages or net profits earned by City residents. The City also receives a portion of the Earned Income Tax assessed by the Pittsburgh Public Schools equal to 2%. — City of Pittsburgh, Earned Income Tax, https://www.pittsburghpa.gov/City-Government/Finance-Budget/Taxes/Tax-FAQs

Practitioner note

BC-to-Pittsburgh is the property tax flip corridor: a lifetime in Vancouver teaches that property tax is small, and Allegheny County's is not. The housing trade still releases cash; the annual carrying cost is a new line item.

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 Pittsburgh 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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