I moved to Canada with a Roth IRA — does Canada tax the growth inside it every year?
By default, yes. CRA's position (folio S5-F3-C1) is that a Roth IRA is not automatically a treaty pension — Canada will tax the accruals annually unless you make a one-time treaty election on your first Canadian return and you stop contributing to the Roth once you become a Canadian resident. Get both conditions right and the Roth keeps its US-style tax-free treatment in Canada.
The two conditions
| # | Condition | Detail |
|---|---|---|
| 1 | One-time election | Claim the treaty pension treatment on your first Canadian tax return after the move — it cannot be made retroactively as a matter of right |
| 2 | No further contributions | Any contribution made while a Canadian resident can destroy the pension treatment for the entire account |
With the election in place and no new contributions, growth inside the Roth is not taxed in Canada, and qualifying US distributions stay tax-free in Canada too.
What breaks it
- Contributing even once as a Canadian resident — the single most common way people lose the treatment.
- Rolling a 401(k) into the Roth after the move (that's a contribution).
- Missing the election on the first return (see the companion article on fixing a missed election).
Frequently asked questions
I made the election years ago and never contributed since. Am I safe?
Yes — the election is one-time and ongoing. Just don't touch the contribution side.
What about a Roth 401(k)?
Same analysis: the treaty looks at whether the arrangement qualifies as a pension. Get advice before moving one across the border.
Does the US care that I made a Canadian election?
No. The election is for Canadian tax purposes; your US treatment of the Roth is unchanged.
Sources
- https://bbs.fcgvisa.com/t/401k-ira/53529
- https://www.canada.ca/en/revenue-agency/services/tax/technical-information/income-tax/income-tax-folios-index/series-5-international-residency/folio-3-cross-border-issues/income-tax-folio-s5-f3-c1-taxation-roth-ira.html (CRA Folio S5-F3-C1)