Once your U.S. tax residence begins, keep the RRSP under its treaty rules but separately plan the FHSA, TFSA, RESP, taxable investments, and Canadian corporation because their Canadian tax labels do not automatically carry into U.S. law.

You will be considered a United States resident for tax purposes if you meet the substantial presence test for the calendar year. To meet this test, you must be physically present in the United States (U.S.) on at least: 31 days during the current year, and 183 days during the 3-year period that includes the current year and the 2 years immediately before that, counting: All the days you were present in the current year, and 1/3 of the days you were present in the first year before the current year, and 1/6 of the days you were present in the second year before the current year.

Green Card Test; First Year of Residency

You are a resident for tax purposes if you are a lawful permanent resident of the United States at any time during calendar year 2025. If you meet the substantial presence test for a calendar year, your residency starting date is generally the first day you are present in the United States during that calendar year. You are a nonresident alien for the part of the year before that date.

Articles IV(2), V(1)-(2), and VII(1)

(a) he shall be deemed to be a resident of the Contracting State in which he has a permanent home available to him; if he has a permanent home available to him in both States or in neither State, he shall be deemed to be a resident of the Contracting State with which his personal and economic relations are closer (centre of vital interests); For the purposes of this Convention, the term "permanent establishment" means a fixed place of business through which the business of a resident of a Contracting State is wholly or partly carried on. The term "permanent establishment" shall include especially: (a) a place of management;

61(a)

Except as otherwise provided in this subtitle, gross income means all income from whatever source derived, including (but not limited to) the following items:

Generally, you are an emigrant for income tax purposes if you meet all the following conditions: You leave Canada to live in another country. You sever your residential ties with Canada. Deemed non-residents are subject to the same rules as emigrants.

If you ceased to be a resident of Canada in the year, you were deemed to have disposed of certain types of property at their fair market value (FMV) when you left Canada and to have reacquired them for the same amount right after. This is called a deemed disposition. This applies to most properties. If the fair market value (FMV) of all of the properties that you owned when you left Canada was more than $25,000, complete Form T1161, List of Properties by an Emigrant of Canada. You must make this election by April 30 of the year after you emigrate from Canada.

Section 4

Election for property of an individual emigrating from Canada on or after March 29, 2010, with respect to which a disposition of the property was deemed to have occurred under Canada's Income Tax Act. The individual must attach Form 8833, Treaty-Based Return Position Disclosure Under Section 6114 or 7701(b), to the U.S. federal income tax return on which the individual reports the deemed disposition.

Sections 4.02 and 5.01

An eligible individual who did not previously make an election under Article XVIII(7) of the Convention to defer current U.S. income taxation on the undistributed income accrued in a Canadian retirement plan will be treated as having made the election in the first taxable year in which the individual was an eligible individual with respect to the plan. Beneficiaries and annuitants of Canadian retirement plans are not required to report contributions to, distributions from, and ownership of a Canadian retirement plan under the simplified reporting regime established by Notice 2003-75 (Form 8891) or pursuant to the reporting obligations imposed by section 6048 (Form 3520).

Article XVIII, paragraphs 8 and 9 explanation

Paragraphs 8 and 9 of Article XVIII address the case of a short-term assignment where an individual who is participating in a “qualifying retirement plan” in one Contracting State (the “home State”) performs services as an employee in the other Contracting State (the “host State”). Benefits are available under paragraph 8 only for so long as the individual has not performed services in the host State for the same employer (or a related employer) for more than 60 of the 120 months preceding the individual’s current taxable year.

If you become a non-resident, you are allowed to keep your existing TFSA. Any income you earn in your account, such as interest, dividends, or capital gains will not be taxed in Canada. However, income you earn through your TFSA may be taxed in your country of residence. Any non-resident contribution you make, except for a qualifying transfer or an exempt contribution, is subject to a 1% tax for each month the contribution stays in the account.

If you become a non-resident of Canada after you open your FHSA, you can continue to participate normally in your FHSA, with one exception: You cannot make a qualifying withdrawal to build or buy a qualifying home while you are a non-resident of Canada. If you are a non-resident of Canada, any taxable withdrawal from your FHSA will be subject to withholding tax in the year of withdrawal. The withholding tax is 25% for non-residents of Canada, unless reduced by a treaty.

Transfers from your FHSAs

You will be allowed to transfer property from your FHSAs to your RRSPs or RRIFs without any immediate tax consequences, as long as it is a direct transfer and you do not have an excess FHSA amount. In order to make a direct transfer, you must not withdraw the property yourself and contribute it to another one of your plans or accounts. To complete a direct transfer from your FHSAs to your RRSPs or RRIFs, fill out Form RC721, Transfer from your FHSA to your FHSA, RRSP or RRIF and give it to your financial institution.

Subscribers cannot deduct their contributions from their income on their income tax and benefit return. The promoter of the RESP administers all amounts paid into the RESP. As long as the income stays in the RESP, it is not taxable. The promoter can return the subscriber's contributions tax-free.

Sections 3, 5.04, and 7

Accordingly, pursuant to the authority granted under section 6048(d)(4), the Treasury Department and the IRS hereby exempt from section 6048 information reporting an eligible individual’s transactions with, or ownership of, an applicable tax-favored foreign trust. This revenue procedure does not affect any reporting obligations under section 6038D or under any other provision of U.S. law, including the requirement to file FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR).

Who Must File; PFIC tests

A foreign corporation is a PFIC if it meets either the income or asset test described next. Income test. 75% or more of the corporation's gross income for its tax year is passive income (as defined in section 1297(b)). Asset test. At least 50% of the average percentage of assets (determined under section 1297(e)) held by the foreign corporation during the tax year are assets that produce passive income or that are held for the production of passive income. A separate Form 8621 must be filed for each PFIC in which stock is held directly or indirectly.

Who Must File; Penalties

U.S. persons (and executors of estates of U.S. decedents) file Form 3520 with the IRS to report: Certain transactions with foreign trusts, Ownership of foreign trusts under the rules of sections 671 through 679, and Receipt of certain large gifts or bequests from certain foreign persons. Generally, the initial penalty is equal to the greater of $10,000 or the following (as applicable).

Categories 4 and 5; When and Where To File; Penalties

For purposes of Category 5, a U.S. shareholder is a U.S. person who owns (directly, indirectly, or constructively, within the meaning of section 958(a) and (b)) 10% or more of the total combined voting power of all classes of voting stock of a foreign corporation, or 10% or more of the total value of shares of all classes of stock of a foreign corporation. In general, a CFC is a foreign corporation that has U.S. shareholders that own, directly, indirectly, or constructively, on any day of the tax year of the foreign corporation, more than 50% of either the total combined voting power or the total value of the stock of the foreign corporation. A $10,000 penalty is imposed for each annual accounting period of each foreign corporation for failure to furnish the required information within the time prescribed.

951(a)

If a foreign corporation is a controlled foreign corporation at any time during any taxable year, every person who is a United States shareholder of such corporation and who owns stock in such corporation on the last day, in such year, on which such corporation is a controlled foreign corporation shall include in his gross income, for his taxable year in which or with which such taxable year of the corporation ends—

Who Must File; Protective Return

Unless one of the exceptions under exceptions from filing below applies or a special return is required, a foreign corporation must file Form 1120-F if, during the tax year, the corporation: Was engaged in a trade or business in the United States, whether or not it had U.S. source income from that trade or business, and whether or not income from that trade or business is exempt from U.S. tax under a tax treaty. A foreign corporation should also file a protective return if it determines initially that it has no U.S. tax liability under the provisions of an applicable income tax treaty.

A U.S. person, including a citizen, resident, corporation, partnership, limited liability company, trust and estate, must file an FBAR to report a financial interest in or signature or other authority over at least one financial account located outside the United States if the aggregate value of those foreign financial accounts exceeded $10,000 at any time during the calendar year reported. The FBAR is an annual report, due April 15 following the calendar year reported. You’re allowed an automatic extension to October 15 if you fail to meet the FBAR annual due date of April 15.

Unmarried taxpayers living in the US: The total value of your specified foreign financial assets is more than $50,000 on the last day of the tax year or more than $75,000 at any time during the tax year. Married taxpayers filing a joint income tax return and living in the US: The total value of your specified foreign financial assets is more than $100,000 on the last day of the tax year or more than $150,000 at any time during the tax year. Married taxpayers filing separate income tax returns and living in the US: The total value of your specified foreign financial assets is more than $50,000 on the last day of the tax year or more than $75,000 at any time during the tax year.

Article VIII, Section 24-a

INDIVIDUAL INCOME TAX PROHIBITED. The legislature may not impose a tax on the net incomes of individuals, including an individual's share of partnership and unincorporated association income.

IRS Form 1116 is used by U.S. citizens, resident aliens, estates, and trusts to claim the foreign tax credit.