Year-End Planning for Cross-Border Filers: The Canada-US Checklist, in the Order the Deadlines Fall

Year-end planning for a cross-border filer is two calendars laid over each other. Some items have a hard December 31 deadline in one country (the RRIF conversion at 71, the pension splitting residency test, the day count, the charitable gift), some have a deadline in the other (the US estimated payment in January, the NR6 before the first rent payment), and some depend on both returns being finished in the right order. The checklist below runs through what has to happen before the year ends, what should happen in the first weeks after, and what is different for someone who moved during the year.

Key takeaways

• Before December 31: count days in each country and adjust travel; realize losses and gains where the timing helps; make RRSP contributions (the deadline is 60 days into the new year, but the deduction planning is now); convert an RRSP to a RRIF if turning 71; withdraw the RRIF minimum; make charitable gifts in the country where they are creditable; close or avoid the TFSA if a US person; spend or transfer the HSA and 529 if moving to Canada; pay Canadian instalments and US estimates due in December and January.
• Right after year-end: file the NR6 before the first rent payment; renew expired W-8BENs and NR301s; gather the Canadian slips and US 1099s; sequence the returns (the country with most of the income first) and extend the other.
• For movers: confirm the departure or arrival date and the ties that support it; make sure the departure-year items (T1243, T1161, T1244, the XIII(7) election, the first FBAR) are in the file; notify every Canadian payer of non-resident status before the first post-move payment.
• For Americans in Canada: confirm the foreign tax credit versus FEIE decision; review the PFIC and foreign trust positions; check the NIIT exposure; plan US estimated payments for any residual.

Before December 31

Days. Count days in the US for the year and the weighted three-year total. A snowbird approaching 183 in the current year loses the closer connection exception; one approaching the weighted 183 gains a filing obligation. A Canadian resident nearing 183 days in Canada as a sojourner (an American spending the year in Canada) becomes a deemed resident. Adjust December travel.

Residency for pension splitting. Both spouses must be Canadian residents on December 31 to split pension income. A couple planning to move in the new year keeps the departure in the new year, not late December.

RRSP. Contributions for the year can be made until 60 days after year-end, but the deduction limit and the decision (contribute, carry forward room, spousal contribution, whether a US person should contribute) are decided now. A US-person contributor tracks basis.

RRIF. An annuitant turning 71 must convert by December 31. The RRIF minimum for the year must be withdrawn by December 31 (the first year after conversion has no minimum). A US-resident annuitant checks the periodic limit for the year and keeps withdrawals under it for the 15% rate.

Gains and losses. Realize losses to offset gains in the country where the gain is taxed; mind the superficial loss (Canada) and wash sale (US) 30-day rules on both sides of the year-end. A Canadian planning a move to a state that taxes gains at ordinary rates realizes gains this year at half inclusion. A US person in Canada with PFICs sells them before year-end to stop the Form 8621 clock.

Charitable gifts. Give to a Canadian registered charity for a Canadian credit; to a US charity for a US deduction; under Article XXI cross-border gifts are limited to the other country's source income; gifts of appreciated securities to a Canadian charity eliminate the Canadian gain. Give by December 31 in the country whose year matters.

TFSA and RESP. A US person closes the TFSA before December 31 to end the year's Form 3520-A obligation the following March. A family with a US-person parent confirms the Canadian parent is the RESP subscriber.

HSA and 529. An American moving to Canada spends the HSA on eligible expenses and uses or transfers the 529 before Canadian residency starts.

Estimated payments and instalments. Canadian instalment due December 15; US estimated payment due January 15. Compute both on the after-credit tax.

Equity. Exercise or defer options with the sourcing schedule in mind; a Canadian moving next year considers exercising before departure.

Estate. Review the US estate exemption use and the Canadian deemed disposition exposure; annual exclusion gifts ($19,000 per recipient; about $194,000 to a non-citizen spouse) must be made by December 31.

Right after year-end

NR6. Before the first rent payment in January for a non-resident's Canadian rental.

W-8BEN and NR301. Check expiry (three years); renew with every payer before the first payment of the year.

Slips and forms. Canadian T4, T4A, T5, T3, T5008, NR4 (by end of February or March); US W-2, 1099, 1042-S (by January 31 or March 15). Reconcile them to the two returns.

Form 3520-A. Due March 15 for a TFSA or RESP foreign trust; extend on Form 7004 if the trust's information is not ready.

Sequencing. File the return in the country with most of the income first (Canada by April 30 for a Canadian resident; the US by April 15 or June 15 for a US resident), pay an estimate in the other country, and extend the other return (US to October 15; Canada has no extension, so a Canadian resident with US income files the T1 by April 30 on an estimate of the US tax and adjusts later).

FBAR. Due April 15, auto-extended to October 15; gather maximum balances from every Canadian account.

For someone who moved this year

Canadian departure. Confirm the date and the ties (home, family, licences, health coverage) that support it. Assemble the departure-year package: T1243 (deemed disposition), T1161 (property list if over $25,000), T1244 (security if deferring), the final T1 with the departure date, the TP-1 if Quebec. Confirm every Canadian payer has been notified of non-resident status and has an NR301. Confirm the home's status (sold, rented under NR6, or vacant with the vacancy tax consequences).

US arrival. Confirm the residency start date (first day of presence in the year the test was met, or the green card date). Decide dual-status versus the full-year election. Prepare the XIII(7) election statement for every deemed-sold asset. Prepare the first FBAR (full calendar year) and Form 8938. Confirm the TFSA was closed, the mutual funds sold, and the corporation wound up (or prepare Form 5471). Prepare the state part-year return.

Canadian arrival. Confirm the arrival date; document fair market values for the deemed acquisition; prepare the Roth election for the first T1; no T1135 in the arrival year; the 60(j) election if rolling a US plan.

US departure. Dual-status final year; close state residency; Form 8854 if expatriating.

For Americans in Canada

Confirm the FTC (not the FEIE) unless the year's facts favour the exclusion; track the carryforward. Review PFICs (sell before year-end; QEF elections where available). Review foreign trusts (TFSA, RESP): the March 15 Form 3520-A. Compute the NIIT on investment income above the threshold; it cannot be offset by the credit; plan the January estimate. Check the child tax credit eligibility for US-citizen children with SSNs. Confirm the RRSP basis record was updated for the year's contributions.

Worked example

A Toronto couple moved to Miami on July 1; he is 70 with a $900,000 RRSP; she has a Toronto condo rented since August; they held a TFSA each (closed in June) and Canadian mutual funds (sold in June).

• By December 31. Count US days (met; residency from July 1). RRSP: not yet 71; no conversion this year; plan the conversion for next year with the NR301 and the periodic limit. Condo: NR6 was filed in July; Section 216 due next June 30. Pension splitting: unavailable (non-resident at December 31). Losses: none to harvest (portfolio deemed sold July 1). Charitable gifts: to a US charity for the US deduction (their Canadian-source income is small). US estimated payment for the resident period by January 15.
• After year-end. Renew the NR301 with the RRSP issuer and the condo agent. Gather the final T1 package (T1243, T1161) and the US dual-status package (XIII(7) election, FBAR, Form 8938). File the T1 by April 30; extend the 1040 to October 15 with an estimate; file the Section 216 by June 30.
• Next year. Convert the RRSP to a RRIF by December 31 (he turns 71); withdraw under the periodic limit at 15%; Florida homestead by March 1.

Official sources

"April 30, 2026: Deadline to file your taxes [...] June 15, 2026: Deadline to file your taxes if you or your spouse or common-law partner were self-employed in 2025 [...] April 30, 2026: Deadline to pay your taxes" — Canada Revenue Agency, Get ready to do your taxes, https://www.canada.ca/en/services/taxes/income-tax/personal-income-tax/get-ready-taxes.html

"If you are a U.S. citizen or resident alien residing overseas or are in the military on duty outside the U.S., on the regular due date of your return, you are allowed an automatic 2-month extension of time to file your return without requesting an extension." — Internal Revenue Service, U.S. citizens and resident aliens abroad, https://www.irs.gov/individuals/international-taxpayers/us-citizens-and-resident-aliens-abroad

"The minimum amount must be paid to you in the year following the year the RRIF is entered into." — Canada Revenue Agency, Registered Retirement Income Fund (RRIF), https://www.canada.ca/en/revenue-agency/services/tax/individuals/topics/registered-retirement-income-fund-rrif.html

Practitioner note

The year-end item cross-border clients miss most often is the one with no form: the day count. The second is the RRIF conversion for the client who turned 71 in the year of the move and assumed the Canadian rules stopped applying. We send every client a two-country checklist in November and a slip list in February, and we set the return sequence before the first slip arrives.

See also: For the full move sequence, read the pre-move planning timeline. Planning a move? Start with the Canada-to-US tax checklist and browse every corridor by city, province, and state.

Next step

Fairlight prepares the year-end review in both countries, the departure-year or arrival-year package, and the return sequencing for the coming filing season. See cross-border pricing or book a call.