What Happens to My Canadian Registered Plans After I Move?

Registered plans are exempt from the departure tax — nothing is deemed sold when you leave. But exemption from departure tax is not the same as continued tax-favoured status: each plan's fate in the U.S. depends on whether the Canada–U.S. treaty recognizes it.

The treaty recognizes pensions. It says nothing about the TFSA, the RESP, or the FHSA — and treaty silence, for a U.S. resident, means full U.S. taxation of accounts Canada still treats as sheltered.

The RRSP and RRIF are the good news: the treaty's pension article preserves tax deferral, and under IRS Revenue Procedure 2014-55 the deferral applies automatically for eligible individuals — no annual election required — though the accounts remain reportable on FBAR and Form 8938. Withdrawals as a non-resident face Canadian withholding under Part XIII: 25% on lump sums, reduced to 15% for periodic pension payments such as qualifying RRIF withdrawals, with the U.S. taxing the income and crediting the Canadian tax. New contributions generally stop making sense without Canadian earned income.

The TFSA loses everything that made it special: its income is currently taxable in the U.S. each year, and depending on its legal form it may attract foreign-trust information reporting, while any Canadian funds inside add PFIC problems. Most cross-border advisors recommend collapsing TFSAs before departure. The RESP faces similar treatment — U.S.-taxable growth and potential trust reporting — softened by the grants already received; families often restructure subscribers or wind plans down depending on the children's situation. The FHSA, newest and unrecognized by the treaty, deserves a pre-departure decision: use it, roll it to the RRSP, or close it.