RRSP vs 401(k) transfer calculator — free calculator
Shows what actually arrives when a retirement balance is moved across a border, after withholding and any offsetting credit.
- 15+Years of cross-border experience
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Shows what actually arrives when a retirement balance is moved across a border, after withholding and any offsetting credit.
Enter your figures
An estimate for planning only. Rates and thresholds used here are the assumptions stated on this page; we confirm every figure against the issuing authority for your own tax year before anything is filed.
How the estimate is built
A cross-border retirement transfer is only worth modelling once you know it is available: the plans have to be of the right type and an election or filing usually has to be made. Where it is available, the arithmetic is withholding at source against contribution room or a treaty deduction at home, with a credit reconciling the two. Leaving the plan where it is, protected by the treaty's deferral article, is frequently the better answer.
How to get this moving
A calculator narrows the range; it does not settle a filing. We will tell you if you do not need us. That happens more often than you would expect.
Reviewed against current guidance for the 2025 and 2026 filing seasons by Udit Gupta, Cross-Border Tax Expert, Legal Quotient Consultants. Written as general guidance, not as a recommendation for your situation. Talk it through with us before acting on it.
Corporate tax calculator, in practice
Read this page for corporate tax calculator. It works through RRSP vs 401 from the beginning — whether it applies to you at all, what has to be filed if it does, and what the engagement costs, priced up front.
The difference a dedicated cross-border team makes
Cross-border is the whole practice
International and cross-border tax is all we do — not a sideline next to domestic work. The edge cases on this page are our ordinary Tuesday.
We say early if it is not our work
If a file needs something this practice does not do, you hear that at the start rather than after a bill.
One team, not two firms billing separately
You are not the go-between for two sets of advisers with two sets of assumptions. One engagement covers each country the file touches.
Residence is tested, not assumed
Where you are resident for treaty purposes is a question with a method. We work through it and write down the answer, with the facts it rests on.
Cross-border situations we are engaged for
Confirming whether a workplace plan could move at all
An engineer who had relocated to Canada wanted a former employer's plan consolidated with a Canadian account. The first step was not the arithmetic but a written enquiry to the plan administrator about whether a transfer of that type was permitted, and on what terms. It was not, on the plan's own rules. The engagement produced a short written note recording that finding, the deferral position under the treaty for the balance left in place, and the reporting to be done each year while it stays there. Nothing was moved.
Reconstructing a withholding credit after the money had gone
A client took a lump sum out of a foreign retirement account and came to us afterwards. The work was reconstruction: obtaining the plan's statement of the amount withheld, establishing how much of the receipt was sheltered at home and how much fell into income, and setting the credit against the resulting liability. Where the credit fell short, we said so rather than presenting the result as neutral. The engagement produced a filed return carrying the foreign tax credit, with the supporting statements retained on file.
Where only part of a retirement balance could be moved
A client held separate retirement accounts abroad and assumed they could travel together. Plan documentation showed they were of different types and only one fell within the transfer rules. We modelled the eligible account on its own and set the other alongside it as a hold-in-place position under the treaty. The engagement produced a decision record for each account separately, a note of the election required for the one that moved, and the annual reporting steps for the one that did not.
Advising a departing client on an existing registered account
A client leaving Canada for the United States wanted to know whether to collapse a Canadian registered account before going. We set out how the treaty's deferral article treats the plan once residence changes, what the receiving country expects to see reported, and the withholding a collapse would trigger on the way out. The engagement produced a written position that the account stay where it was, with the reporting obligations on the other side listed year by year so nothing was discovered late.
Modelling a transfer against simply leaving the balance alone
A client asked for a comparison rather than a recommendation. We built the two columns side by side from their own figures: withholding taken at source on the amount leaving, the proportion sheltered on receipt by contribution room, the credit reconciling them, and against that the deferred position if nothing was done. The engagement produced the comparison in writing, the assumptions each column rested on, and a note of which assumptions had to be confirmed with the plan administrator before anyone acted.
Sorting the sequence of elections before any funds moved
A transfer had been agreed in principle between two institutions and was about to be processed. The concern was order: the election that shelters the receipt has to be in place around the movement of the funds, not after them. We set out the sequence, identified the documents the source institution had to issue for the credit to be claimed later, and held the instruction until each was confirmed. The engagement produced a dated checklist both institutions worked to, and a complete evidence file.
A Retirement Plan That Grows Tax-Deferred in Only One Country
Cross-border retirement accounts are recognised by treaty, but the deferral usually has to be elected rather than assumed. The engagement checks whether the election was made, makes it where it was missed, and reports the account on whichever side requires it.
Read how this one runsThe Same Income Taxed Twice on Paper
Relief usually exists and is lost to sequence: one country taxes at source and the other credits it, and preparing them in the wrong order claims a credit against a figure nobody has computed.
Read how this one runsAll case studies — every published engagement in one place.
Core International & Cross-Border Tax Services
International Tax Planning & Advisory
Strategy and compliance for income, assets and families spread across borders.
U.S. & Cross-Border Tax Returns
Expat & Emigration Tax
Non-Resident Canadian Tax
Transfer Pricing & BEPS
Tax Treaties & Withholding
Cross-Border Estates & Trusts
Global Investments & Reporting
Cross-Border Corporate Tax
India Tax for NRIs & Returning Residents
Canadian Tax with a Foreign Element
UAE Tax for Expats & Their Home Country
Industries & Client Types We Serve Worldwide
Global E-commerce & Marketplaces
- Foreign VAT / GST / sales tax registrations
- Marketplace withholding reviews
- Inventory nexus & PE analysis
- Multi-currency books reconciled
Technology & SaaS
- Cross-border revenue sourcing & withholding
- IP structuring with real substance
- Equity for cross-border teams
- U.S. expansion: entity & PE setup
Professional Services Firms
- Reg 105 / 102 waivers
- Permanent establishment risk
- Partner mobility planning
- Cross-border withholding recovery
Cross-Border Real Estate
Foreign property income and sales are taxed in both countries by default; Section 216, FIRPTA and treaty credits are the standing toolkit.
Property is taxed where it sits, which is the one rule no treaty overrides. What the treaty does decide is the credit, the rate on the rent and what happens on the sale — and the clearance certificate on a disposition is applied for before closing, not after the buyer has already held the money back.
- Section 216 rental returns
- FIRPTA withholding recovery
- Section 116 clearance
- Treaty credit optimization
Importers, Exporters & Manufacturers
- Transfer pricing documentation (s.247)
- Customs value vs transfer price
- Foreign affiliate reporting (T1134)
- Country-by-country reporting
Athletes, Artists & Entertainers
- Reg 105 & U.S. CWA agreements
- Multi-state & country calendars
- Touring income allocation
- Royalty & image-rights withholding
Remote Workers & Digital Nomads
- Residency analysis before moving
- Employer payroll exposure
- Totalization & social security
- Foreign tax credits
Investment Funds & Holding Companies
- Treaty access & PPT reviews
- FAPI & surplus computations
- Withholding-efficient routing
- Governance & substance
