One Plan, Two Countries: Wealth Strategies for Canadians in California

Take charge of your financial future with an integrated cross-border wealth strategy built for Canadians who now call California home. You need one cohesive plan—not a patchwork of advice— to successfully navigate CRA and IRS filings alongside California Franchise Tax Board rules and to coordinate RRSPs, TFSAs, 401(k)s, RSUs, and real estate on both sides of the border. We help you align investments, minimize double taxation, address community property and estate considerations, and ensure your wealth transfers smoothly—no matter which jurisdiction applies. Our specialized cross-border team turns complex, high-tax California realities into clear, actionable opportunities and strategies to confidently grow, protect, and ultimately pass on what you’ve built.

Key Cross-Border Issues for Canadian Expats in California

Navigating cross-border living between Canada and California requires careful planning across multiple areas. You may face dual tax filings in Canada, the U.S., and California, each with its own residency and conformity rules. Retirement accounts, such as RRSPs, TFSAs, 401(k)s, and IRAs, have conflicting tax treatments, especially at the state level. Public pensions like CPP, OAS, and U.S. Social Security also require coordination under treaty provisions. Investment choices matter, too. California taxes capital gains as ordinary income and federal PFIC rules penalize Canadian mutual funds. The legal stakes and financial risks increase as you factor in community property considerations, estate planning, health coverage gaps, real estate reporting, and immigration residency traps. Proactive strategic planning ensures 100% compliance, minimizes tax exposure, and protects long-term wealth.

Tax and Financial Planning Challenges

Dual Tax Filing (CRA, IRS and FTB)
You may need to file timely returns in three different jurisdictions. California taxes its residents on worldwide income and follows its own conformity rules—so a federal/treaty break may not apply at the state level. Know when to file Form 540 or 540NR and whether or not you qualify for California’s “546-day” safe harbor exclusion when you spend extended time outside the state.
Retirement Account Conflicts
(RRSPs, TFSAs, 401(k)s, IRAs) Federal treaty rules let you defer RRSP income on your U.S. return, but California generally does not respect that deferral—taxing annual earnings inside Canadian plans. TFSAs are also taxable in the U.S. and California. Plan asset location and distributions accordingly.
CPP, OAS & U.S. Social Security Coordination
Public pensions also cross borders. Map out how CPP/OAS interact with U.S. Social Security (timing, withholding, and potential clawbacks) to understand where each stream will be taxed under treaty rules. (We’ll model both sides before you file.) cks and fill coverage gaps.
Currency & Investment Pitfalls (PFICs, Capital Gains, Advisor Limits)
California taxes capital gains as ordinary income, and federal PFIC rules can punish Canadian mutual funds/ETFs if you hold them in personal accounts. Before year-end, be sure to review structures (like U.S.-custodied accounts) and election choices.

Real Estate, Estate Planning and Retirement Life

Community Property & Estate Planning
California is a community-property state—each spouse may have a 50% interest in income and assets acquired during marriage. That affects separate filings, trusts, and cross-border estate documents, but a revocable living trust is a common tool to avoid California’s long, expensive probate.
Health Insurance Coverage
Once you are a resident of California, your provincial health plans no longer cover you. Use Covered California, the state’s ACA marketplace, or employer coverage, and plan for how to manage coverage gaps if you expect to move back to Canada.
Real Estate & Rental Income
Are you selling or earning income from California property while a nonresident? The state generally withholds 7% of CA-source payments (including many real estate deals—Form 593). Cross-border rentals require careful reporting on both sides.
Residency & Immigration Traps
The U.S. Substantial Presence test determines federal tax residency, but California has its own unique residency tests. Missteps—like staying too many days in-state or keeping key ties—can cause you to be taxed as a resident. However, the FTB safe harbor can help if you’re away on a long work contract.

Cross-Border Financial Clarity: Guidance for Canadians in the U.S.

Cross-border financial planning is essential for the more than 800,000 Canadians residing in the U.S.

In this video, John McCord, Vice President and Portfolio Manager at Cardinal Point Wealth Management, shares practical strategies to help you:

Navigate Canada-U.S. tax rules
Coordinate accounts like RRSPs and 401(k)s
Plan smarter with cross-border investment strategies
Leverage the Canada-U.S. Tax Treaty to avoid double taxation

Are you living, working, or retiring in the U.S. as a Canadian? Without expert help, trying to manage finances across two countries—especially taxes, investments, and retirement planning—can be extraordinarily complex. Cross-border financial planning is essential for the more than 800,000 Canadians residing in the U.S.

Cardinal Point offers personalized solutions, multicurrency reporting, and integrated guidance to support every step of your dual-nation financial journey. If you’re balancing life across borders, this video is a must-watch. Learn how Cardinal Point can help you create a secure, tax-efficient future in both countries.

Guidance for Canadians Living, Working, or Snowbirding in California

Stay ahead of the curve and fully informed with expert strategies for Canadians who own property, pay taxes, or plan to relocate between California and Canada. The articles below dive into the critical pre-immigration steps every Canadian should know before crossing the border—like accelerating income, realizing gains, and restructuring corporations before U.S. residency begins. We unpack the IRS reach into gifts, estates, trusts, and PFIC-heavy portfolios. We explain the traps in CFC and GILTI rules, and the five-figure penalties tied to FBAR, Form 8938, and more. You’ll also find guidance on avoiding costly mismatches when passing wealth to U.S. heirs, timing RRSP/RRIF withdrawals, and using treaty elections to protect cross-border estates. Whether you’re planning your move to the Golden State or safeguarding assets for the next generation, these insights deliver clarity and confidence for tax-smart decisions on both sides of the border.

Move Smart, Not Fast: Pre-Immigration Tax Planning for Canadians Heading South

Thinking about trading Canadian winters for U.S. opportunities? Before you cross the border, we want you to know that the IRS taxes more than income. The moment you become a resident, U.S. taxes can extend to gifts, estates, trusts, PFIC-heavy portfolios, and closely held companies. At Cardinal Point Wealth, we explain why timing is everything. Before day one, accelerate income, realize gains, defer losses, restructure foreign corporations, and review trusts. We unpack CFC, GILTI, and PFIC traps, the domicile test for transfer taxes, and the alphabet soup of forms—FBAR, 8938, 3520, 5471—where penalties start at five figures. You’ll see how treaty elections, pre-immigration gifts, and coordinated advice from your Canadian professionals preserve wealth and simplify first-year compliance. Move smart, not fast: start early, build a cross-border team, and enter the U.S. on your terms, not the IRS’s. Read the full article now to protect your assets and your future self.

Before You Bequeath: The Cross-Border Tax Maze Canadians Must Navigate

Leaving assets to a child or grandchild in the U.S. isn’t just a line in your Will—it’s a complicated cross-border tax event. Canada deems a disposition at death; the U.S. may ignore that basis reset, taxing your heir on the full gain. Add to that complexity PFIC-laden portfolios, Canadian private corporations that morph into CFCs, and “foreign trust” rules with Forms 3520/3520-A, and you’ve got an intricate maze of punitive rates, throwback rules, and five-figure penalties. We break down the biggest traps: basis mismatches, PFIC compliance, CFC/Subpart F/GILTI exposure, and trust residency pitfalls. Then we show effective ways to structure gifts vs. bequests, time your RRSP/RRIF payouts, and use the international tax treaty and smart trust design to protect assets on both sides of the border. If your legacy crosses 49°N, plan before you sign. Start early, coordinate advisors, and spare your heirs costly surprises. Read the full post now—and share it with the family that needs to understand it.

How a Cross-Border Financial Advisor Protects Your Wallet—Whether You’re Living or Snowbirding in California or Moving There

What We Tackle		How it Cuts Your Bill
Sale & Purchase Structuring Ownership entities, FIRPTA planning, and California real-estate withholding (Form 593, 3.33% default)		Reduces or refunds federal FIRPTA and state withholdings, optimizes basis/Prop 13 protections, and limits future estate-tax exposure
Retirement-Account Alignment RRSPs, TFSAs, 401(k)s, IRAs, CPP, OAS, Social Security		Preserves deferral where possible, avoids TFSA/PFIC surprises, and sequences withdrawals to keep both U.S. and California taxes in check
Currency & Cash-Flow Strategy Staggered FX conversions, multi-currency portfolios, USD “income buckets”		Adds potential “currency alpha” and softens CAD/USD swings—while managing California’s ordinary-income treatment of capital gains
Health-Care & Snowbird Planning Covered California vs. provincial plans, Medicare timing, Substantial Presence & CA residency tests/safe harbors		Ensures you’re insured on both sides, avoids accidental CA residency (and taxation) when you winter away, and times exits cleanly
Estate, Gifting & Community Property Roadmap Cross-border Wills/trusts, community-property splits, QDOTs, beneficiary audits		Shrinks probate headaches, preserves step-ups, and shields heirs from unintended U.S. estate and California probate costs

Experience financial clarity despite borders. With one seamlessly coordinated strategy, our cross-border specialists integrate Canadian and U.S.—as well as California-specific—tax, investment, and estate rules into a single, easy-to-follow roadmap. Stop wrestling with forms and start enjoying winters in California, summers up north, and every milestone in between.

Life in the Golden State California:
An Innovation Hub for Canadian Professionals

California is synonymous with creativity, scale, and ambition. Opportunity is boundless and beckons globally-minded talent, all the way from Silicon Valley’s tech giants and startups to Hollywood’s entertainment machine and San Diego’s biotech corridor and the state’s booming clean-energy and aerospace sectors.

Increasing numbers of Canadian professionals—engineers, scientists, founders, creatives, academics, and executives—are being actively recruited or transferred to California, or choose it as their U.S. base for its deep capital markets, world-class universities, and entrepreneurial culture. The rewards can be significant—but so can the complexity.

Relocating (or even spending part of the year) in California without updating your tax, investment, and estate structures can trigger unexpected state taxes, community-property implications, and cross-border compliance headaches. Coordinating CRA, IRS, and California Franchise Tax Board rules, rethinking how RRSPs, TFSAs, 401(k)s, and equity compensation fit together, and aligning Wills and trusts with both nation’s legal systems are all essential first steps.

Why Work with a Cross-Border Advisor

Anyone who has tried to find an advisor who is legally licensed or authorized to provide financial advice on both sides of the U.S.-Canada border knows how difficult that search can be. Few firms comply with applicable regulations or have the appropriate structure in place. And those that do rarely have a qualified team dedicated exclusively to Canada-U.S. cross-border financial planning issues. At Cardinal Point, we are different. We have developed a service model and platform that is specifically designed to meet the needs of Canadians living in the United States, U.S. citizens living in Canada, Canada-U.S. dual citizens, and American and Canadian expatriates living abroad. Because we specialize in these areas, we have the ability to oversee all of your Canada-U.S. cross-border financial planning complexities.

Understand the benefits of working with a Cardinal Point cross-border financial advisor

Canadians Living in the U.S.

Whether you are transitioning residency between Canada and U.S. or you have already made the move but continue to hold investment assets or financial interests in both Canada and the United States, proper cross-border financial planning can integrate and coordinate the asset management of your investments, reduce taxes and maximize your estate.

Tax Planning

Our tax planning initiatives are fully integrated with our clients’ investment, financial and estate planning strategies. This coordinated approach to wealth management streamlines the financial planning process and helps our clients ensure lasting wealth for today, tomorrow and generations to come.

Investment Management

Goal based investing is a key tenet of our belief system. Instead of promoting performance chasing strategies, we believe strongly in a disciplined, customized portfolio design process focused on client objectives, targeted returns, and a strict adherence to client risk tolerances.