What to do with your 401(k) once you live in Canada
Many people still hold a 401(k) or 403(b) after relocating to Canada and are unsure of their options. There are four, and one of them is clearly better than the rest.
Many people who move to Canada still hold a 401(k) or 403(b) and are unsure what to do with it. Here are the four choices after relocating to Canada, with the trade-offs of each.
1. Keep the 401(k) in the U.S.
You can maintain your 401(k) in the U.S. However, you run the risk of receiving a notice from the brokerage company or the custodian of your plan giving you 30 to 90 days to close your account or arrange for its liquidation. That can result in a significant taxable event, in some cases with up to a 30% withholding tax bill. The reason is that some U.S. firms are not licensed to deal with a Canadian resident client.
2. Cash it out
Although you would get money right away, the size of the tax payment would create a sizable reduction in your retirement funds: in some instances up to 30% withholding tax, plus a 10% penalty if you are under 59½.
3. Transfer the 401(k) or IRA to an RRSP
Due to U.S. withholding taxes, this is difficult and may result in double taxation without proper tax consultation. This type of transfer does not use the RRSP room you established. For instance, if you had a $100,000 401(k) you were planning to transfer to an RRSP, you would instead move it to an IRA.
4. Roll the 401(k) to an IRA at a firm registered to serve Canadian residents
Roll the 401(k) into an IRA held at a firm that is registered in both countries and can manage it for a Canadian resident. The rollover itself is not taxable if done directly, the account keeps its tax-deferred status, and the firm handles the U.S. and Canadian reporting. Only a small number of firms offer this, they charge advisory fees, and you should confirm the firm’s registration in your province before transferring. Many cross-border planners favour this route because it avoids the tax hit of options 2 and 3 and the forced-liquidation risk of option 1.
Sources and further reading
- IRS, Rollovers of retirement plan and IRA distributions
- IRS Topic 557, Additional tax on early distributions (the 10% tax before age 59½)
- IRS Publication 515, Withholding of Tax on Nonresident Aliens
- CRA, Certain lump-sum payments from a foreign retirement arrangement (transfers to an RRSP under paragraph 60(j))
- IRS Publication 597, Information on the United States–Canada Income Tax Treaty
Related resources
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Chris is a cross-border financial advisor licensed in both Canada and the United States. He helps Americans moving to Canada and Canadians moving to the U.S. keep their retirement accounts intact and build one plan that covers both sides of the border. He writes for Cross Border Wealth in his personal capacity.
Disclosure: Chris writes in his personal capacity; his views do not represent any firm he is associated with. Cross Border Wealth does not provide advisory services. If you need advice, use the Get connected form and we will introduce you to a licensed professional.

