US retirement accounts, estate plans, and investment structures do not automatically survive a move to Canada. The two countries share a border and a language but operate under entirely separate financial and tax systems; and the decisions made before you leave determine whether your existing structures are protected or become expensive problems.

In this episode, Arielle Tucker, CFP®, EA sits down with Brian Wruk, MBA, CFP® (US), CFP® (Canada), TEP, CIM, RFP®, founder of Transition Financial Advisors Group and author of The American in Canada. Brian is a dual citizen who moved his American wife to Canada, navigated the compliance requirements firsthand, and has been doing US-Canada cross-border planning since 1997.

Topics covered, include:

• Why moving to Canada does not end your US tax obligations
• The Roth IRA rules that can protect your retirement savings across the border
• The TFSA trap that creates phantom US taxable income
• How revocable living trusts can trigger Canadian taxes
• What Canadian healthcare actually looks like in 2026, including 3-year waits for a primary care physician in Ontario
• How to plan for retirement across two countries
• The one thing Brian tells every client before they board the plane

The conversation covers the Roth conversion window that closes the moment Canadian residency begins, why TFSAs generate phantom US taxable income that foreign tax credits cannot offset, how revocable living trusts can trigger punitive Canadian taxation, and what Canadian healthcare actually delivers in 2026; including current wait times for primary care and what private options are beginning to emerge.

Resources

• Connect with Brian Wruk at Transition Financial Advisors Group: passporttowealth.com/brian-wruk
• Are you a qualified professional serving US expats in France or Europe? Apply to passporttowealth.com/join
• Subscribe to the Passport to Wealth newsletter: passporttowealth.com/contact
• Find a vetted cross-border advisor: passporttowealth.com/directory

Mentioned in this episode:

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Welcome to Passport to Wealth.

I'm your host, Arielle Tucker, certified financial planner and fellow US expat.

On this show, we bring together cross-border experts and global Americans to help you

make confident decisions about your life, your money, and your next move abroad.

Let's get started.

Welcome back to Passport to Wealth.

My name is Arielle Tucker.

If you're an American thinking about moving to Canada right now, and a lot of

people are, the assumption most people make is that it's an easy move.

Same continent, similar culture, English speaking, while there is some French speaking, as you and I know Brian.

And then they get there and they realize the financial system isn't an entirely different world.

He's a CFP in both countries and a dual citizen.

He's written the books, literally the Canadian and America and the American and Canada.

And he founded Transition Financial Advisors Group specifically for people making this crossing.

Brian, thank you so much for joining us on Passport to Wealth today.

It's my pleasure, Arielle.

No problem at all.

I'm happy to talk about what I love.

You know, when we first jumped on this call, I was surprised because you have very much a heavy Canadian accent.

I know you're currently based in Arizona, correct?

I am in Arizona now.

Yeah.

So.

So talk me through your own personal transition from Canada to the US.

Yeah.

Well, it's an interesting journey.

Believe it or not, I've always had a fascination with the United States and I have wanted to move down there.

And even in high school, I was part of the band.

I played percussion and we took a band trip down to Portland, Oregon.

And I just, I love the trip and thought, man, this is kind of interesting.

And then in grade 12, I did a trip with campus life down to LA where we experienced

nottsbury farm and Disneyland, the oceans, the beaches, the warm weather.

And at that point in time, I was, I was hooked.

And so I said, you know, when I got back to Canada, I started playing jobs at Disney and everything out of high school.

You know, I was a little bit naive.

And I just have always been fascinated and wanted to live in the United States.

I eventually, you know, that dream kind of died.

I didn't, you know, nobody's going to pay to immigrate me down there to work in Disney.

Well, that was my question.

I was like, we're high schoolers able to immigrate.

Not to age your brain, but I wasn't sure if immigration was an easier.

No, it's a big issue, of course.

It's one of the things that we've dealt with over the years, you know.

So I let that dream kind of die for the moment and I joined the telephone company in Canada and started working there.

And then I had a chance to do my graduate work.

And so I applied to several, several schools in the United States and I ended up

getting accepted at University of Southern California and University of Arizona.

And a friend of mine who I grew up with in Shurapark, Alberta,

just outside Edmonton was teaching in the economics department at

University of Arizona.

So I called him up and he said, yeah, come down here.

Tuition was better, you know, that kind of thing.

So I packed the truck and drove down and I ended up meeting my wife there.

And we kind of went, you know, sort of traveling a little bit back and forth between

Canada. She met my family.

We eventually got married at the end of my graduate work.

And for some reason that befuddles me to this day, we move back up to Canada.

I had a job as on the leave of absence.

My company has supported me.

And so we moved to Calgary and that's when I learned some of the complexities of

moving an American citizen to Canada.

And we were just poor students.

So we didn't have much money and that kind of thing, but having to file a tax return for her every year,

married, filing separately, declaring foreign accounts, which wasn't that big a deal back then.

It is now.

So yeah, it was, it was a taxing little exercise.

And then I realized after four years in Calgary and my wife is from Arizona, she didn't like

the weather, that kind of thing.

I realized I'm waking up next to a green card every day.

So we moved down that path.

And as a Canadian married to an American citizen, once you've been married for three years and have

a green card, I'm eligible for citizenship.

So she went and got a green card and moved down to the States and started then with a company

called Keats Connolly and Robert Keats is a Canadian.

He's kind of the grand papier, Canada, US planning.

His firm is now no longer in existence.

He's retired.

I worked for them.

So I read his book.

He was in Arizona.

of being in the United States.

And so, and then working right in this area with Canadians looking to relocate to both countries

back and forth.

That's how I cut my teeth in this business.

So that's kind of my journey.

I mean, you know, I say this all the time, especially in our past, part to wealth community.

People who have lived the experience approached the planning differently because it's so much more

than just a financial plan.

It is all of the lived life experience of how do you move?

How do you navigate all of that?

What's the emotional side of things?

That's really the important piece.

Absolutely.

The experience of being, again, born or raised in Canada, learning the culture and that and then

moving back and forth and getting experience the most.

And then actually moving yourself.

So I moved my wife to Canada and then we moved back down to the States and dealing with things

like immigration, customs, like getting her up there when we landed, we were told, well, you've

basically be broken like three immigration laws.

We had to get a minister's permit at the time to allow her into the country and to show our wedding,

you know, getting a better certificate, I should say.

And so it was just, yeah, that's when my eyes were open to the complexity of this whole thing.

You know what I mean?

So you're absolutely right.

Experience matters and it matters a lot.

Did you find it was easier to move into Canada or into the US was was one move one way easier than the other?

The move to Canada was easier.

She didn't require a whole lot of sort of the medical background.

When I moved to the States, I had to get X-ray to make sure I didn't have TB.

I needed to get a medical clearance and a lot of that kind of stuff.

That would be only part that I'd say is a little bit more difficult.

I don't know what that's like today.

The current administration, I think that's a little bit more difficult and they're scrutinizing things a little bit greater detail.

Actually, that kind of is a good transition point talking about kind of how policy can impact immigration.

What are you seeing from your clients?

Like who are we have?

I call them mixed families, right?

You have one who is the citizen of the US or Canada and then one who isn't.

How are you seeing that?

Or how are you helping support families through those transitions across right now?

You know, it's interesting in my career.

There's always something that will trigger either people to move to Canada or they will move from Canada to the United States.

So, for example, when same-sex marriage was approved in Canada, we got a lot of calls of people wanting to move up there for obviously same-sex marriage.

Then they approved that down here.

The oil industry, when the price of oil was really high and the exchange rate was more imperative.

You saw more people sort of moving down.

This way from particularly Alberta Saskatchewan down to Houston, Dallas, Oklahoma.

We got a lot of business that way.

What we're seeing now is with the current administration eliminating a lot of the DEI.

We have a lot of the LGBTQ plus community moving up to Canada and parents of trans kids.

We've done a lot of work in that area the last while.

So it just depends on what's happening, you know, and what.

Everybody has their reason for moving to whatever country.

Some people were getting a lot of calls now.

Oh, the Liberals are in power in Canada again and they want to move.

That's fine.

We are agnostic when it comes to reasons why.

But people have their own individual reasons and we respect that and we'll help them with the complexities of that move, you know.

So things have changed.

But from your observation and working with all these families, do you think it's become more complex to live and invest across both countries or is it?

Is it kind of held steady and it just kind of depends on who's in power and what the what the rules are at that time?

The complexity is still there, particularly when the IRS brought in all the fatke rules that added a lot more complexity because you have the report of foreign accounts.

You know, a lot of that stuff.

What's happened though is I think the industry has changed to be able to accommodate and work with those people a little bit better.

You know, Schwab has got a pretty good international department.

Now a lot of these custodians are now being a little bit more flexible or develop policies and procedures to allow IRAs to remain in the United States, for example.

So that's been a big improvement in being able to service these people.

Do you often see the same families are moving across multiple multiple times or do people kind of move and settle? What kind of trends do you see?

We're seeing more people are moving and staying.

This current administration has got a lot of people questioning that have moved down here and they're considering moving back without a number of clients sort of say, you know what?

Kind of done with the states, but it's generally for lifestyle reasons.

The current administration is pushing some of that, that thinking, but it's getting them to go, you know what?

And we don't really have much for friends here anymore.

We're retired.

We're going to move back where we have family.

And that's one of the primary things, Arielle, that I tell clients, you never move to save taxes or to do it as a lifestyle decision.

Do you want to be closer to family, to grandkids, to children?

You know, what's the lifestyle?

And that's basically the essence of what we do and what financial planning is all about.

Where are you going?

Where are you at?

How are you going to get there?

Is it feasible?

And so helping clients understand what their overall lifestyle is, you know, and saying, look, if you move to Canada, we can run a set of financial projections for you to say, yeah, you know what, with your net worth and your nest egg, you're going to still be able to live up there.

Maybe the taxes are higher, that kind of thing.

But who cares?

You want to get closer to family?

That's what's important at the end of the day, you know, yeah.

We do some of our long term care planning with people down here.

So if your spouse were to pass away, for example, where would you want to go live?

Would you stay in Houston or would you move up to Calgary?

Well, I probably want to be closer to Calgary because I have kids that can come visit me that kind of thing.

Okay.

Well, that's something that we need to look at, you know.

Mm hmm.

Yeah, actually, can we talk about that a little bit?

Because I am really curious, right?

And I grew up going down to Florida and you would see all the snowbirds.

A lot of them are for Canada.

I remember that very like hanging out and meeting all these Canadians on vacation every year.

So I am really curious, how do you guys navigate that for families who maybe have their retirement plans and then someone passes away in the US and they decide to go repatriate?

What does that process look like?

Yeah.

If they were working with us, we generally get a good US estate plan in place.

There's a couple of oops and aha moments in that.

So for example, if you move from Canada down to the States and set up a revocable living trust, which is a common state planning tool down here, they're not aware of the non-resident trust rules in Canada that basically, if you leave Canada, set up a trust with a Canadian beneficiary in it within five years of moving.

Canada then deems that trust taxable in Canada.

So it's a little bit tricky from that perspective.

And again, this is where the niche exists, just like yours.

There's these little oops and aha moments.

So they move down.

Oh, and a state planning attorney, you got to go see that.

Yeah, we'll set up a trust and they don't realize about some of these landmines and trust their tax very punitively in Canada.

So that's one thing.

I just want to better understand that process.

Right.

Yeah.

You move, you have your retirement plan, right?

We kind of have the go-go years, the slow go years, and then we have the no go years.

And once we get into those no go years, you might not want to be sitting on the beach in Florida anymore.

You might want to be up and near your daughter or your kids or your grandkids right back in Canada.

And so I'm just curious, like, how do you plan for those kind of different periods in retirement?

Yeah.

So, I mean, the big thing is, is that, for example, some of like a state planning, you basically got to wind up your revicable living trust and move everything out of it before you move because trust their tax very punitively in Canada.

That's one thing.

You generally, your brokerage account, your after tax account has to be moved up to Canada.

So making sure you have the right investments in there to begin with is something that's really important.

For example, you can't transfer mutual funds up there.

So those all have to be liquidated, causing a, you know, a tax burden down here.

So if you can just transfer wholesale, that's another thing to look at.

Tracking cost basis when you enter Canada, you get a step up in basis of all your assets, taxable assets, when you enter Canada.

Now you got to track that in Canadian dollars.

In the US dollars, you have to track in US dollars and has a different cost basis from when you originally bought it.

You know, that kind of thing.

So there's just a lot of planning and thinking you have to do.

And I understand, I mean, you're moving for lifestyle, but you're not moving to a tax haven in Canada with tax rates of 50% plus.

It behooves you to do some pre-entry planning.

You know, for example, one idea is maybe you want to look at incurring some tax now, rolling an IRA to a Roth.

Roth's made it in the last fifth protocol of the Canada US tax treating last negotiations in the equivalent in Canada is called a tax free savings account, TFSA.

That did not make it into the treaty.

So Roth IRA's remain their tax free status when you move to Canada, as long as you don't make a contribution to it when you are in Canada.

Otherwise you lose all the tax free status.

Another oops and aha.

Wow, that's a gotcha.

Right.

So then, but the TFSA everybody say, oh, you need to set up a TFSA.

It's tax free.

We got to got to look at the numbers because TFSAs are fully taxable in US.

So now you have phantom income that you're not allowed to take foreign tax credit against.

So now you're paying out of pocket down there.

So those are the kind of things you got to be aware of, but it may make sense, especially if you can plan in advance.

Like we've helped clients that say, you know, in three, four years, I'm planning and moving back up to Canada.

Be closer to family and that kind of thing.

We'll do Roth conversions every year emptying out a whole 800, you know, a thousand million dollar IRA into a Roth.

Yeah, they're paying tax every year, but they get up there and all that money is tax free from a from a Canadian perspective.

So, yeah, that's a that's a big one, for example.

That's a huge one.

And I'm so glad you did.

This was a great example because this example obviously applies to Canada.

But I also see this with pretty much every country that we work with, where we have these unequal and balanced systems.

Somehow, Canada has decided to accept the Roth right in the treaty, but then on the US side, they didn't accept the equivalent program.

I see that all the time, right?

And then every single one of these agreements is different.

So it's a perfect example of a classic gotcha.

So thank you for that excellent example.

OK, I want to talk a little bit about what your 50% plus tax rate is getting you in Canada.

And the thing that I always hear about, right, and I grew up in New York just across the border about an hour away from the Canadian border.

I would always hear about the health care, free health care in Canada.

Can you speak a little bit to kind of what is what is free health care in Canada actually mean?

And what was what is your experience with that?

Yeah.

So basically, it is socialized medicine is socialized health care.

So everybody has access to the health care system up there.

All you have to do is show your, in my case, it was my Alberta health care card.

And in you go, you can go to the ER.

They have now some more like sort of urgent care clinics, that kind of thing.

The main problem is, though, is that you need a primary care physician that kind of governs and can then help you get into the ER.

It's a hospital and that kind of problem is that they're so short of primary care physicians that they're waiting period right now.

Places like Ontario's three years.

So you're only three years to get a primary care physician.

You get a primary care physician.

Whoa.

OK.

So your choice then when you need medical care is generally to just go to the ER.

Well, though that system is overburdened.

And so and you probably read stories recently of people bleeding out in the ER,

guy having a heart attack in the ER and passing away.

You know, the wait time is eight hours, 16 hours, sometimes to get care.

So that's one of the problems.

Canadian health care has been a source of pride for Canadians for a long period of time.

You know what I mean?

And it should be.

I mean, the fact that, you know, universal health care, you can go in and get care is great.

But the system has deteriorated over the years, I think, with the increase

and expenses, the burden on the system with the boomers and that kind of thing.

Plus under the Trudeau years, Justin, that is they allowed a lot of immigration.

I think there's probably what I think a million or two million people that were

immigrated into Canada.

It's created quite a burden on the system per se.

So unfortunately, the system is kind of deteriorated a bit.

I'll give you a case in point.

So my aunt was in the hospital and it's happened to be up visiting family.

And we went to the Royal Alexander Hospital in Edmonton, great hospital.

I've been in that hospital many a time.

And we went up and we got the doors open to the unit and there's like carts and

trays and patients and, you know, stretchers and everything sort of down the hallway.

We went and asked like, where's my aunt?

And so over this room here, we went around and it's a four bedroom unit.

And my aunt was the fifth bed stuck in the corner kind of in the dark.

OK, and they just are so over over capacity.

And so we visited with her and I went to leave.

I gave her a hug and I kind of like auntie you.

They've been like giving you sponge baths or whatever here.

And she's like, well, no, but they're really busy and that kind of thing.

And she was, I'm hoping one of the lady over here is supposed to move because

then I can get, you know, bed by the window and that kind of thing.

So there's been it's just a real influx and a burden on the system.

And I know they allowed a lot of the immigration, that kind of thing, but they

need to invest also in infrastructure, which the schools, this hospitals, the roads,

a lot of that.

I'm not sure that they've caught up with that.

So there's been a bit of a deterioration and actually people are living there

or people are considering moving there are actually starting to question, OK,

why am I paying all these taxes?

If I'm getting less service and the services deteriorate, particularly in

healthcare, why am I, why am I paying these higher tax rates?

I'm curious.

Is there like a private insurance option?

Like if someone's moving into Canada and they're like, look, I can't wait three

years for a service.

Can they access like a private system in a way or what?

There is some of that going on.

Yeah.

And it's being built out and it's funny because a lot of the members of parliament

are crossing the crossing the border, getting their MRIs done, getting their

CAT scans done because the waiting period is so long in Canada for a lot of that

in non-destructive testing.

And the other thing too, is a lot of hospitals along the border are offering

package deals for people.

Like you want a knee replacement?

Come on down.

Twenty five thousand dollars will replace your knee, help you get rehab and then

send you back.

But there is now there's a lawsuit and Quebec a number of years ago that

basically authorized private care to start coming in.

And so that is start making its way across Canada.

There's still restrictions on it, but it is in a start to make its way.

There's private again, CT scans, MRIs, a lot of that stuff now is starting to happen

up there.

And a lot of concierge type doctors as well, where you can pay privately and

and that kind of thing.

So yeah, I think it's such an important consideration.

If you're moving across borders to really think through what are you going to get

from a healthcare perspective?

I mean, I grew up in the States.

So I was used to, you know, US medical care.

We moved to Germany for a while and it was very affordable, right?

Paying through through government insurance.

But the quality that you would receive is different, right?

It's a different system, right?

They pay for it differently.

Your experience is different, different.

And so we ended up doing like an additional like private supplement.

And I just tell people to really understand what your expectations are and

make sure whatever you're expecting that that's like aligned.

Because if you're expecting, you know, US gold standard, you know, you'd a corporate

health insurance package and you go anywhere else in the world, you may have a very

different experience.

Yeah.

In my experience, and I guess that I've been doing this for 30 somewhat years and

I've been in the hospital and medical system in Canada.

I've been in the hospital and medical system here in the US.

In my opinion, I think it is a combination of both systems that is probably the ideal.

And I think that's kind of where they've ended up, like in places like France and

Germany.

So you have a basic universal health care, which I'm not a fan of socialized medicine,

but I don't know how you get to universal health care without going through the

socialized medicine weed path, you know what I mean?

I think there's a common where here you got people that can get basic care.

Carolyn McLanahan is an advisor here in the United States and she was a physician

turned advisor and she's come up with plans on how we could get universal health

care here relatively easy, but then have a private system for those that can afford

it to go ahead and do that.

You know, the system in the United States is very expensive, but you do get care and

you get access.

And so I think some kind of a combination between the two is probably the ideal

solution of what you're going to get.

But with Congress being so divided and not much is getting done in that area,

unfortunately.

I do, I will say on that note, I am very thankful to not have to see the Go

Fund Me's or when I see Go Fund Me's for people on Facebook that I went to high

school, like it seems like living in Europe, it's like, Oh my God, I can't

believe you have to like ask for help.

You have people help pay your medical bills.

Like it now like living outside of that for so long.

It seems like a crazy thing that we have to do in the US.

And so yeah, it's my opinion.

There's a lot of and again, if we can just some some preventative care, that

would solve a lot of the problems.

And so yeah, and you know, if you're an entrepreneur and you come out of

university and you want to create something, well, how do you get health care?

So you have a lot of people running around with no health care, which puts a

burden on, you know, the hospitals, because they have to treat you or you get a wrongful

death suit or something like that.

You know, it's it's a real problem in Canada.

If you're an entrepreneur, you can go starting on that.

You have health care.

You have your Alberta health care card or O-HIP card, you know?

So yeah, it's definitely both systems need to be improved for sure.

Yeah.

Okay.

Well, thank you so much for sharing that.

I know we went a little over into health care, but I want to just ask you one final

question.

If you were, if someone was to approach you about moving from one side to the

other, it doesn't matter.

What would be one tip of advice that you would tell them right now?

Do your planning, you know, a move from Arizona to California or California to

Arizona is not like a move from Montana to Alberta.

The laws and the things that you need to be aware of, these oops and aha moments,

seek out the right advice in advance and do your planning if you can.

I mean, I literally have had people, you know, call me up and say, Hey, I'm

interested in getting some planning.

I'm, I'm, you know, moving to Canada.

What should I be looking out for?

And I said, well, when are you moving?

Well, I'm in the airport in New York.

I'm about to get bored of playing.

I'm kind of going, we're, you know, we're going to handcuff at this point.

There's not a lot you can do, but think it through.

Read my book.

There's a lot of information online now, at least educate yourself a little bit.

And then you have to make a decision.

Do you want to do something on your own to figure out yourself?

Do you want to do something where you can get an hourly engagement, which we

don't necessarily do, or do you want to hire an advisor that's going to help you

plan it, do it before, during and after your move and hand hold you through the

whole process?

And if you want to move back, we can continue to help you all the way back.

That's, that's one of the main things is just the pitfalls and you don't know

what you don't know.

And that's where the biggest problem comes in.

Yeah.

And I know so many of us cross-border advisors, we started our careers because

of the pain points that we experienced, right?

We had to figure it out.

I was also married to a poor student when we first moved abroad.

And I am so thankful we were broke when we had to figure it all out because there

wasn't a lot of money at mistake, at stake when we were making mistakes.

And learned so much from moving, moving back and forth and then, yeah,

exactly.

Yeah, a narrative about it.

And the culture too, you understand things.

I mean, being from America, you understand.

And, and it's the same thing, you know, on our staff now, we've got, you know,

an American that moved up to Canada.

We've got another one born and raised in my hometown of Edmonton now living in

the States.

And we've got employees.

We're hiring Canadians now.

We've got our tax lead in, in Alberta.

And so, and we got somebody in Nova Scotia.

And, but we've got people that have lived at real life experience and, and that

there's, there's technicians accordingly.

So it's been a pleasure sort of mentoring and coaching people along the years as well.

You know, so love what I do.

And you love what you do.

There's nothing to retire from.

So Brian, you are such an OG in this space.

Thank you so much for joining us on Passport to Wealth.

I really appreciate it.

My, my pleasure.

Thanks for the invite.

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