A 2026 plain-English guide to how each of your Canadian registered accounts behaves once you become a U.S. resident.

Your Canadian registered accounts do not all cross the border the same way. One is well protected by the tax treaty, one becomes a tax and paperwork problem, and one is new enough that many advisors have not thought it through. If you are moving to the United States, here is how the RRSP, the TFSA, and the FHSA each behave once you get there.

Your RRSP: keep it, but report it

The RRSP is the good news. The Canada-U.S. tax treaty specifically recognizes it, so you can generally keep your RRSP after moving to the United States and its growth continues to be tax-deferred for U.S. purposes while the treaty election is in place. You do not have to collapse it before you leave.

What changes is reporting and withdrawals. As a U.S. resident you will have U.S. information reporting to attend to for the account, and any RRSP withdrawal has both Canadian non-resident withholding and U.S. tax to coordinate through the foreign tax credit so the same money is not taxed twice. Kept and planned, the RRSP travels well.

Your TFSA: tax-free in Canada, not in the U.S.

The TFSA is the trap. The United States does not recognize it as a tax-free account, so once you are a U.S. person the income and gains inside your TFSA can become taxable on your U.S. return, erasing the account’s entire advantage. Worse, the U.S. may treat a TFSA as a foreign trust, which can bring onerous information returns and real filing cost.

For many people moving south, the TFSA is worth more collapsed before departure than kept, precisely because its benefit does not survive the border and its cost can be significant. That is a decision to make deliberately, with advice, before you go, because contribution room and timing matter.

Your FHSA: newer, and similar concern

The First Home Savings Account is recent, and it raises the same core issue as the TFSA. The United States does not have a matching account and may not treat its growth as tax-free, so a U.S. person could face U.S. tax and reporting on an account that is tax-free in Canada. Because the FHSA is new, guidance is still thin, which is all the more reason to get specific advice on your account rather than assume it behaves like an RRSP.

The decision framework

• RRSP: usually keep it, rely on the treaty, and plan withdrawals and reporting.
• TFSA: often close it before you leave, because the tax-free benefit does not cross the border and reporting can be costly.
• FHSA: get specific advice; treat it with the same caution as the TFSA until your situation is confirmed.
• In every case: decide before you become a U.S. resident, not after, because timing changes your options.

Each of these decisions interacts with the others, which is why they are best made as part of one coordinated cross-border plan rather than account by account.

Frequently asked questions

Can I keep my RRSP if I move to the U.S.?

Yes. The Canada-U.S. treaty recognizes the RRSP, so you can generally keep it and its growth stays tax-deferred for U.S. purposes with the treaty election in place. You take on U.S. reporting and need to coordinate any withdrawals across both countries.

What happens to my TFSA when I move to the U.S.?

The U.S. does not treat the TFSA as tax-free, so its income can become taxable on your U.S. return and it may be treated as a foreign trust with extra reporting. Many people are better off closing the TFSA before moving south, but decide with advice first.

Is the FHSA treated like the RRSP or the TFSA in the U.S.?

Closer to the TFSA in terms of concern. The U.S. has no equivalent and may tax its growth, so treat it cautiously and get specific advice, especially since guidance on this newer account is still limited.

Talk to a cross-border specialist

The order in which you keep, close, and report your Canadian accounts before a move to the U.S. can save or cost you a great deal. Sartorial Wealth can build that sequence for your accounts.

Moving south with Canadian registered accounts?

We can sequence what to keep, what to close, and what to report, before your residency changes and your options narrow. Book a call with Sartorial Wealth, a dual-registered cross-border wealth manager: Book a call

Sartorial Wealth is a cross-border wealth management practice serving families and individuals who live, work, or invest across the Canada-U.S. border. This article is for general information only and reflects rules and figures current as of 2026. It is not tax, legal, or investment advice. Cross-border rules are complex, change over time, and depend on your specific facts and residency. Please speak with a qualified cross-border advisor before acting.