Answered September 2026

With your current 401(k) contributions, an RRSP or FHSA contribution does not lower your 2026 U.S. income tax; your pre-tax 401(k) lowers Canadian tax only if you remained Canadian-resident and meet RC268, not if you emigrated in June.

“I moved from Canada to Colorado in June 2026 and will make about $55k for the rest of the year. I'm contributing $250 biweekly to a US 401k and want to contribute $8k to either a Canadian RRSP or FHSA. Does contributing to a Canadian RRSP reduce my US taxes, and do my US 401k contributions reduce my Canadian taxes?”

Summary

If you truly emigrated in June, your later Colorado wages are normally outside your Canadian departure return, so there is no Canadian tax for the related 401(k) contributions to reduce. You can still use a traditional 401(k) for current U.S. and generally Colorado income-tax relief.

Your best route depends first on whether Canada treated you as an emigrant in June and then on whether your 401(k) contributions are traditional or Roth.

Use a traditional 401(k) for U.S. reliefU.S. tax now

Traditional, pre-tax 401(k) contributions reduce current U.S. federal taxable income; Colorado generally begins with modified federal taxable income. The 2026 employee-deferral limit is $24,500 across applicable plans, although your plan may set a lower limit (IRS 401(k) Contribution Limits; Colorado Individual Income Tax Guide).

Use RRSP or FHSA room for Canadian taxCanada only

An RRSP contribution may be claimed on Canada’s line 20800 up to your RRSP deduction limit. An FHSA contribution is generally deductible for its contribution year or a future year, but you must have opened the account while Canadian-resident; an existing FHSA can continue after nonresidency (CRA RRSP and FHSA guidance).

Claim a personal RRSP on the U.S. returnNot deductible

Your ordinary personal RRSP is not a treaty , and U.S. domestic law limits the individual deduction to qualified retirement contributions. The treaty’s special relief is also unavailable for the same service period while you contribute to your 401(k) (Treaty Article XVIII(8)(f); IRC 219; Treasury Technical Explanation).

Claim an FHSA on the U.S. returnNot deductible

An FHSA is an individual arrangement without employer involvement, so it fails the treaty definition used for cross-border retirement-plan contribution relief. It does not provide a U.S. or automatic Colorado contribution deduction (Treaty Article XVIII(15)(b); IRC 219; Colorado Individual Income Tax Guide).

Deduct the 401(k) in Canada if still residentResident only

If you remained Canadian-resident, Form RC268 permits a Canadian deduction when your U.S.-service wages are taxable in the United States, the employer is U.S.-resident or has a U.S. permanent establishment, and the contributions relate to those services. The deduction is capped by U.S. tax relief and your remaining RRSP room after RRSP deductions (Form RC268; Treaty Article XVIII(10)).

Moving physically does not by itself settle Canadian tax residency; the emigrant and continuing-resident branches must be kept separate.

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Watch out for

Canadian residency controls the Canada answerIf you became an in June, Canada requires worldwide income only through your departure date and generally taxes only Canadian-source income afterward. Your later Colorado wages—and the 401(k) contributions tied to them—therefore do not reduce Canadian tax; if you remained Canadian-resident, the RC268 branch may apply instead (CRA, Leaving Canada; Form RC268).
Traditional and Roth 401(k)s differTraditional 401(k) contributions are made with before-tax dollars; designated Roth contributions are after-tax. Only the traditional contribution gives current U.S. federal income-tax relief, which generally flows into Colorado’s modified-federal-taxable-income starting point (IRS Roth Comparison Chart; Colorado Individual Income Tax Guide).
RRSP claims can crowd out RC268 roomIn the Canadian-resident branch, the RC268 deduction cannot exceed the U.S. tax relief or your remaining RRSP deduction room after deducting actual RRSP contributions. Claiming an $8,000 RRSP deduction could therefore reduce or eliminate the Canadian room available for your 401(k) deduction (Form RC268, page 1).
The treaty RRSP exception is narrowAn ordinary personal RRSP is not a treaty . Even a qualifying group or rollover-funded RRSP cannot receive Article XVIII(8) relief for a service period in which you also contribute to a qualifying U.S. plan such as your 401(k) (Treaty Article XVIII(8)(f); Treasury Technical Explanation).
Foreign-account relief is not a deductionThe IRS’s Canadian-retirement-plan reporting relief does not turn an RRSP contribution into a U.S. deduction and does not waive Form 8938 or FBAR obligations. An FBAR is required when your aggregate foreign financial accounts exceed US$10,000 at any time during the year; the 2026 FBAR is due April 15, 2027, with an automatic extension to October 15, 2027 (Rev. Proc. 2014-55; FinCEN).
You may be unable to open an FHSA nowYou must be a Canadian resident when opening an FHSA. If you opened one before becoming nonresident, CRA says you may continue participating, but you cannot make a qualifying home-purchase withdrawal while nonresident (CRA FHSA guidance).
A June arrival may produce a dual-status returnIf you remained in the United States after arriving in June and your days are not excluded from the substantial-presence calculation, you will generally meet the U.S. residence test for 2026. A person who becomes a U.S. resident during the year and is resident on December 31 generally files Form 1040 marked “Dual-Status Return” with a nonresident-period statement; citizenship, green-card status and excluded days can change this result (IRS Substantial Presence Test; Taxation of Dual-Status Individuals).

Next steps

These steps separate the two countries’ tax periods and put each deduction on the return where it can legally work.

Before choosing the Canadian account

Separate your Canadian resident and nonresident periods

Use the emigrant branch if you left Canada to settle in Colorado and became nonresident: report worldwide income through departure and only Canadian-source income afterward. Use the continuing-resident branch if Canada still treated you as resident after the move; that is the only branch in which the post-move 401(k) deduction under RC268 can apply.

Requirements

Your June 2026 departure date
Dates your Colorado home and employment began
Details of any home, spouse or dependants remaining in Canada

Before the final 2026 payroll elections

Confirm whether the 401(k) is traditional or Roth

Keep traditional/pre-tax and Roth amounts separate. Traditional contributions receive current before-tax treatment; Roth contributions do not. Keep total 2026 employee elective deferrals within the $24,500 federal limit across applicable plans, subject to any lower plan limit.

Requirements

Your plan contribution election
2026 payroll statements
Contributions to any other employer deferral plan

By December 31, 2026 for a 2026 FHSA deduction

Choose the Canadian contribution for its Canadian result

For an RRSP, claim contribution receipts up to available room on line 20800 of the Canadian return. For an FHSA, contribute only if you were Canadian-resident when the account was opened and have participation room; a contribution intended for the 2026 deduction must be made in 2026 because first-60-days FHSA contributions cannot be carried back. Neither choice creates a U.S. deduction under your current facts.

Requirements

Your RRSP deduction limit from CRA records
Your FHSA participation-room statement
The FHSA opening date, if one exists

For the 2026 Canadian return

Prepare the correct Canadian-return branch

If you were an emigrant, exclude post-departure Colorado wages from worldwide-income reporting and do not claim their 401(k) contributions as a Canadian deduction. If you remained Canadian-resident, calculate RC268 using only contributions tied to U.S.-taxable employment services and cap it at the lesser of U.S. relief and remaining RRSP room; the current 2025 form carries the amount to line 20700, while CRA’s final 2026 form and line were not yet published on September 12, 2026.

Requirements

Canadian and U.S. employment dates
U.S. wage records
401(k) contribution statements
Employer’s U.S. residence or permanent-establishment facts

After year-end

Prepare the U.S. return and FBAR

If you became a U.S. resident during 2026 and remained resident on December 31, file Form 1040 marked “Dual-Status Return” and attach the nonresident-period statement. File the 2026 FBAR electronically if aggregate foreign accounts exceeded US$10,000 at any time; it is due April 15, 2027 and automatically extended to October 15, 2027. RRSP reporting relief does not waive Form 8938 or FBAR, and FHSA-specific U.S. treatment remains unresolved.

Requirements

Your 2026 U.S. travel-day calendar
Citizenship, green-card and visa details
Highest 2026 balances of all non-U.S. accounts
RRSP and FHSA statements

Others who faced this

You are not the first to go through this. Here is how it went for others who asked the same thing.

Legal sources

These conclusions come from the Canada–U.S. Income Tax Treaty and Treasury Technical Explanation, CRA forms and guidance, the Internal Revenue Code and IRS guidance, Colorado’s official tax guide, and FinCEN.

U.S.–Canada Income Tax Treaty, Article XVIII(8)(f)

The treaty’s temporary-assignment relief is unavailable for a period when the worker also contributes to a qualifying plan in the work country, such as a 401(k).

U.S.–Canada Income Tax Treaty, Article XVIII(8)(f)

Article XVIII(8)(f), pages 15–16

(f) With respect to contributions and benefits that are attributable to services performed during a period in the individual's current taxation year, no contributions in respect of the period are made by or on behalf of the individual to, and no services performed in that other State during the period are otherwise taken into account for purposes of determining the individual's entitlement to benefits under, any plan that would be a qualifying retirement plan in that other State if paragraph 15 of this Article were read without reference to subparagraphs (b) and (c) of that paragraph.

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Treasury Technical Explanation of 2007 Canada Protocol

Ordinary personal RRSPs are excluded; specified group and rollover-funded RRSPs can qualify.

Treasury Technical Explanation of 2007 Canada Protocol

Explanation of Article XVIII(15) and General Note paragraph 10

Thus, U.S. individual retirement accounts (IRAs) and Canadian registered retirement savings plans (RRSPs) are not treated as qualifying retirement plans unless addressed in paragraph 10 of the General Note (as discussed below). Paragraph 10 of the General Note provides that the types of Canadian plans that constitute qualifying retirement plans for purposes of paragraph 15 include the following and any identical or substantially similar plan that is established pursuant to legislation introduced after the date of signature of the Protocol (September 21, 2007): registered pension plans under section 147.1 of the Income Tax Act, registered retirement savings plans under section 146 that are part of a group arrangement described in subsection 204.2(1.32), deferred profit sharing plans under section 147, and any registered retirement savings plan under section 146, or registered retirement income fund under section 146.3, that is funded exclusively by rollover contributions from one or more of the preceding plans.

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U.S.–Canada Income Tax Treaty, Article XVIII(15)(b)

An individual account without employer involvement cannot qualify for the treaty’s retirement-contribution relief.

U.S.–Canada Income Tax Treaty, Article XVIII(15)(b)

Article XVIII(15)(b), page 19

(b) That is not an individual arrangement in respect of which the individual's employer has no involvement; and

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CRA Form RC268 (2025)

This is the Canadian-resident route for deducting qualifying U.S. 401(k) contributions, including its conditions and cap.

CRA Form RC268 (2025)

page 1

You can deduct your contributions to your U.S. retirement plan on your Canadian income tax and benefit return if all of the following conditions are met: • The remuneration you received for the services you performed as an employee in the U.S. is taxable in the U.S. • Your employer is a resident of the U.S. or has a permanent establishment in the U.S. • The contributions are attributable to the services you performed as an employee in the U.S., for which you received U.S. taxable remuneration, and are made during the period you performed those services The amount you can deduct cannot be more than the amount of tax relief available in the U.S. or your registered retirement savings plan (RRSP) deduction room remaining after you deduct any RRSP contributions for the year. Add this amount to the amount on line 20700 of your return.

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CRA Leaving Canada (Emigrants)

An emigrant reports worldwide income through departure and generally only Canadian-source income afterward.

CRA Leaving Canada (Emigrants)

You have to report your world income (in Canadian dollars) for the part of the year that you were considered a resident of Canada. After you leave Canada, as a non-resident, you pay Canadian income tax only on your Canadian source income.

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CRA Line 20800—RRSP Deduction

An RRSP receipt may produce a Canadian deduction, but only up to available RRSP deduction room.

CRA Line 20800—RRSP Deduction

Line 20800

If you have received any contribution receipts, you may claim these as a deduction at line 208 00 of your income tax and benefit return up to your RRSP deduction limit.

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CRA Opening Your FHSAs

Canadian residence is required when opening an FHSA.

CRA Opening Your FHSAs

To open an FHSA, you must be a qualifying individual by meeting all of the conditions below when you open your account. You are a resident of Canada. If you do not meet all of the conditions above, you are not a qualifying individual and cannot open an FHSA.

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CRA Non-residents and FHSAs

A previously opened FHSA may continue after emigration, but qualifying home withdrawals are unavailable while nonresident.

CRA Non-residents and FHSAs

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.

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CRA FHSA Tax Deductions

FHSA contributions may create a Canadian deduction, but unlike RRSP contributions they have no first-60-days carryback.

CRA FHSA Tax Deductions

Contributions that you make to your first home savings accounts (FHSAs) are generally deductible on your income tax and benefit return for the year of the contribution or a future year, similar to registered retirement savings plan (RRSP) contributions. Over your lifetime, the most you can deduct from your income as an FHSA deduction is $40,000. Contributions that you make to your FHSAs during the first 60 days of the year cannot be deducted on your income tax and benefit return for the previous year, unlike contributions to an RRSP.

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26 USC 219

U.S. domestic law allows an individual deduction only for defined qualified retirement contributions.

26 USC 219

26 USC 219(a), (e)

In the case of an individual, there shall be allowed as a deduction an amount equal to the qualified retirement contributions of the individual for the taxable year. For purposes of this section, the term "qualified retirement contribution" means— (1) any amount paid in cash for the taxable year by or on behalf of an individual to an individual retirement plan for such individual's benefit, and (2) any amount contributed on behalf of any individual to a plan described in section 501(c)(18).

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IRS Roth Comparison Chart

Traditional 401(k) payroll contributions give current pre-tax treatment; Roth contributions do not.

IRS Roth Comparison Chart

Designated Roth employee elective contributions are made with after-tax dollars. Traditional, pre-tax employee elective contributions are made with before-tax dollars.

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IRS 401(k) Contribution Limits

The 2026 employee 401(k) deferral cap is $24,500 across applicable plans.

IRS 401(k) Contribution Limits

Deferral limits for 401(k) plans

The limit on employee elective deferrals (for traditional and safe harbor plans) is: $24,500 in 2026, subject to cost-of-living adjustments. Generally, you aggregate all elective deferrals you made to all plans in which you participate to determine if you have exceeded these limits.

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Colorado Individual Income Tax Guide

Colorado generally starts its individual-income-tax calculation from modified federal taxable income.

Colorado Individual Income Tax Guide

Individual Income Tax Guide

In general, Colorado imposes an income tax on the modified federal taxable income of each individual, whether they are a Colorado resident, a nonresident, or a part-year resident.

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IRS Taxation of Dual-Status Individuals

This gives the filing mechanics when someone becomes a U.S. resident during the year and remains resident at year-end.

IRS Taxation of Dual-Status Individuals

You must file Form 1040, U.S. Individual Income Tax Return, if you are a dual-status taxpayer who becomes a U.S. resident during the year and who is a resident of the U.S. on the last day of the tax year. Write "Dual-Status Return" across the top of the return. Attach a statement to your return to show the income for the part of the year you are a nonresident.

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IRS Substantial Presence Test

The substantial-presence test may make a continuous June arrival a U.S. tax resident during 2026.

IRS Substantial Presence Test

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

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Revenue Procedure 2014-55

The RRSP reporting procedure removes certain Form 3520 obligations but preserves Form 8938, FBAR and other reporting requirements.

Revenue Procedure 2014-55

Sections 5 and 6

Subject to any future guidance that may be issued by the Treasury Department and the IRS, beneficiaries (regardless of whether they are “eligible individuals” within the meaning of section 4.01 of this revenue procedure) and annuitants 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). This revenue procedure does not, however, affect any reporting obligations that a beneficiary or annuitant of a Canadian retirement plan may have 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), imposed by 31 U.S.C. § 5314 and the regulations thereunder.

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FinCEN FBAR Requirement

Foreign accounts are aggregated for the US$10,000 FBAR threshold.

FinCEN FBAR Requirement

A United States person that has a financial interest in or signature authority over foreign financial accounts must file an FBAR if the aggregate value of the foreign financial accounts exceeds $10,000 at any time during the calendar year.

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FinCEN FBAR Due-Date Clarification

The FBAR has an April 15 deadline and automatic extension through October 15.

FinCEN FBAR Due-Date Clarification

The annual due date for filing FBARs for foreign financial accounts is April 15. The Act also allows an extension of the filing deadline of up to six months. FinCEN will grant filers failing to meet the FBAR annual due date of April 15 an automatic extension to October 15 each year. Accordingly, specific requests for this extension are not required.

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These are the official rules as published on the cited dates; rules change.

This is general information about official processes, not legal advice, and SettleKit is not a law firm.

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