Levy Salis LLP is proud to share this latest Step Journal publication by Kevyn Nightingale, LLM, CPA, CA (ON), CPA (IL), TEP, and Shlomi Steve Levy, B.A., LL.B., J.D., TEP, examining the often-misunderstood tax treatment of Canadian retirement plans when a plan holder becomes a resident of the United States.
Cross-border retirement planning between Canada and the United States is rarely straightforward — and Canadian RRSPs and RRIFs are no exception. What many taxpayers and advisors assume to be a simple treaty deferral can, in practice, expose unexpected tax consequences once US tax rules come into play.
In this article, Kevyn Nightingale LLM, CPA, CA (ON), CPA (IL), TEP and Shlomi Steve Levy B.A., LL.B., J.D., TEP analyze the “zero-investment” provision and the deferred taxation of income accrued in Canadian retirement savings plans, highlighting why commonly accepted approaches may warrant closer scrutiny.
The content below is just an excerpt. For full insights and to ensure compliance with the latest regulations, download the complete article by clicking the link below.
Kevyn Nightingale, LLM, CPA, CA (ON), CPA (IL), TEP
Shlomi Steve Levy, B.A., LL.B., J.D., TEP
Step Journal
January 28, 2026
Retirement, recalculated
What is the issue?
Reporting distributions from Canadian registered retirement savings plans (RRSPs) and registered retirement income funds (RRIFs) in the United States is more complicated than one may think. Beneath the surface, there are hidden risks that can materially affect tax outcomes if not properly understood and managed.
What does it mean for me?
Members — particularly those advising on cross-border tax matters or preparing US tax returns for individuals with RRSPs and RRIFs — need to be aware of these risks and how they may impact clients with Canadian retirement assets.
What can I take away?
It may be worth reconsidering use of the treaty’s deferral of RRSP income.
Download the full article (PDF) to read the complete analysis and explore the practical implications for cross-border retirement planning.
The comments offered in this article are meant to be general in nature and are not intended to provide legal advice regarding any individual situation. Before taking any action involving your individual situation, you should seek legal advice to ensure it is appropriate for your circumstances.
About the author
Kevyn is a cross-border tax practitioner with over 35 years’ experience focusing on the intersection between individuals and entities with international tax issues.
His work spans the practical and the academic. He speaks and writes on Canadian and US tax issues, most regularly for Wolters Kluwer (CCH), the Society for Trust and Estate Practitioners and the Canadian Tax Foundation. He has published over 100 papers, including three in major journals that were peer-reviewed.
Shlomi Steve Levy is a Partner of Levy Salis LLP and is a member of the Quebec Bar, the Law Society of Ontario (L3), the Society of Trust and Estate Practitioners, and the Canadian Bar Association.
