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Old May 15th 2014, 2:12 pm
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Default Re: US v. Canada on taxes

Originally Posted by Steve_
This thread: http://britishexpats.com/forum/showt...6#post11258636 encouraged me to do my annual comparison of "how much tax would I pay if I lived in the US". Because basically the winter makes me think of moving then I do this comparison and I no longer want to.

Anyway, it is a very illuminating comparison because when I work through it, two things become immediately apparent - the US has way higher payroll taxes and has way lower thresholds for pension contribution, correct me if I'm wrong but in the US the maximum IRA contribution is $5,500 and in Canada it's up above $20,000 (a proportion of your income up to that).

You can itemize your deductions in the US and there is the mortgage tax credit but you've got to be going some to make up the difference in the pension tax credit and the payroll taxes.

However - if you live off of investment income, you probably aren't contributing to a pension and there is no payroll tax, and if you live in a State with no income tax then the marginal rates are lower in the US than anywhere in Canada. So on that basis, you would be better off, bearing in mind though that CGT in Canada is 50% of the income tax rate whereas the short-term CGT rate in the US is the income tax rate (so plan carefully in other words).

If you're self-employed though you get absolutely hammered in the US compared to Canada because you've got to pay both halves of FICA and in Canada although you have to pay both halves of CPP, you're exempt from paying EI (which is federal, unlike the US). And CPP is at a massively lower rate than FICA.

The downside being of course that Social Security pays out way more than CPP does.

Canada also has no estate tax, in case you're thinking of dying.

So what I take from this is that if you're a rich dude who has investment income you're better off in the US but if you're a working stiff you're better off in Canada. Provided you remember to contribute to your pension.
As someone else pointed out, you forgot about 401k contributions in the US. Also, many US employers match employee 401k contributions to some degree - free money. I would pay much more for gas, restaurants, beer, electronic goods and a host of other things in Canada. Also sales tax is higher in Canada. You'd have a hard time convincing me that I'd be financially better off in Canada. I lived and worked in the GTA for 7 years and I'm much better off financially here in the greater Washington DC area (not exactly one of the cheaper areas in the US).
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Old May 16th 2014, 8:28 am
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Default Re: US v. Canada on taxes

Originally Posted by MarylandNed
As someone else pointed out, you forgot about 401k contributions in the US.
Which I agreed with later on - but there's a massive difference in payroll taxes.

Also, many US employers match employee 401k contributions to some degree - free money.
Not a fair comparison because I assume most don't and like I said there are a blizzard of pension schemes and whatnot to muddy the water. An RRSP doesn't have as many restrictions as a 401(k), for example.

I would pay much more for gas, restaurants, beer, electronic goods and a host of other things in Canada.
Strangely we were just having this discussion in the Canada section and someone mentioned this website: http://www.numbeo.com/cost-of-living...&city2=Calgary

Although if you put in Baltimore, it's less.

Also sales tax is higher in Canada.
Depends where you are, it's not consistent across either the US or Canada. In Alberta for example we only have 5% GST, but it applies to services and certain food items which are usually exempt in the US - but on the other hand, the rate is often higher than 5% in the US.

You'd have a hard time convincing me that I'd be financially better off in Canada. I lived and worked in the GTA for 7 years and I'm much better off financially here in the greater Washington DC area (not exactly one of the cheaper areas in the US).
Toronto v. DC
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Old May 16th 2014, 2:02 pm
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Default Re: US v. Canada on taxes

Originally Posted by Jsmth321
Now I have no investments, no retirement plans of any sort, so its straight income from employment, but looking at an old pay stub from 2010 in California, the withholding amounts are basically the same, and my refunds in both countries is basically the same at around 300 or so.

Overall because medical care is cheaper in Canada, I am financially better off in Canada.
US have an option to buy health insurance or not to buy health insurance. If you are healthy and want to go to doctor only once a year then US (no health insurance option) is better. There are more job opportunities,more investment options. Low real estate interest rates and some places in USA have low GST.
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Old May 16th 2014, 4:10 pm
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Default Re: US v. Canada on taxes

Originally Posted by Steve_
The thing with an SEP IRA though is that there is a 10% tax penalty if you withdraw before you're 59.5 years old, whereas with an RRSP you just have to pay income tax so it's purely a tax deferred savings plan.
Not just the SEP IRA - same for other IRA's as well, and 401k's too.

No idea what an RRSP is...presumably something in Canada? Not intending ever moving there, so can't be arsed to google it Whats this thread aiming at - is someone trying to weigh the pro's and cons of either country for a potential move, or is it just a neh neh neh neeeh ne thread?
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Old May 16th 2014, 9:36 pm
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Default Re: US v. Canada on taxes

Originally Posted by Yorkieabroad
Not just the SEP IRA - same for other IRA's as well, and 401k's too.

No idea what an RRSP is...presumably something in Canada? Not intending ever moving there, so can't be arsed to google it Whats this thread aiming at - is someone trying to weigh the pro's and cons of either country for a potential move, or is it just a neh neh neh neeeh ne thread?
RRSP is a Registered Retirement Savings Plan.

http://www.cra-arc.gc.ca/tx/ndvdls/t...rrsps-eng.html

Originally Posted by economy_1
US have an option to buy health insurance or not to buy health insurance. If you are healthy and want to go to doctor only once a year then US (no health insurance option) is better. There are more job opportunities,more investment options. Low real estate interest rates and some places in USA have low GST.
Few people stay young and healthy for life, and eventually need healthcare, and no matter how you slice it, this will end up costing more in the long run in the US, and nobody can plan for a catastrophic medical emergency such as a heart attack, so only a fool goes without insurance in my opinion in the US.

I spent 24 years in the US, most in California, and financially is makes more sense to be in Canada for me, as I am also not willing to live in places like Texas or the south where the lower cost of living tends to be.

I was only speaking for myself, and Canada offers me more for employment through higher wages, and less costs for healthcare which is something I need and cannot go without and would be a financial burden in the US.

I don't care about real estate, my income is not sufficient in either country to buy real estate so its of no concern or interest for me.
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Old May 17th 2014, 9:01 am
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Default Re: US v. Canada on taxes

Originally Posted by Jsmth321
RRSP is a Registered Retirement Savings Plan.

http://www.cra-arc.gc.ca/tx/ndvdls/t...rrsps-eng.html

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Oh OK, thanks.

Not really sure why I wandered into this thread.......

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Old May 18th 2014, 1:27 pm
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Default Re: US v. Canada on taxes

Originally Posted by Steve_
Deemed dispositions though is not in the same league, plus there is no gift tax either. You can easily avoid deemed dispositions by disposing of your assets which you can't do if there's a gift tax.
Canada considers gifts to be a disposal for capital gains tax purposes. (There are exemptions for gift to charities, etc.). Which, if it's a capital asset, leads to a capital gains or loss for the donor.
http://www.cra-arc.gc.ca/E/pub/tg/t4037/t4037-e.html

Last edited by JAJ; May 18th 2014 at 1:37 pm.
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Old May 22nd 2014, 10:49 am
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Default Re: US v. Canada on taxes

Yes, the point I was getting at is that there is capital gains generally speaking on disposal of capital assets, but if you dispose of those assets then they're not "deemed" to be disposed of when you die, so you've avoided that problem at least. Capital gains is an issue in either country so no real net difference there although the rates are somewhat different.

The idea behind deemed dispositions is that you cannot avoid CGT through death or emigration, the US has a similar method of doing it for people who give up citizenship iirc.

Given that your residence is usually your principal asset that would be subject to CGT, but is exempt, and so are RRSPs and RRIFs, then it's not really a major issue for most Canadians.

Admittedly estate tax isn't either as you have to have a net worth of more than $5.25 million (or twice that if married).

No province though has an estate tax, but some States do.
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Old May 22nd 2014, 10:52 am
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Default Re: US v. Canada on taxes

Originally Posted by Yorkieabroad
Whats this thread aiming at - is someone trying to weigh the pro's and cons of either country for a potential move, or is it just a neh neh neh neeeh ne thread?
I was drawing a comparison because every year when I do my taxes it is at the end of winter so I start thinking about moving to the US, and then when I work out what the tax bill would be in the US, the miser in me takes over.
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Old May 22nd 2014, 8:38 pm
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Default Re: US v. Canada on taxes

Originally Posted by Steve_
Yes, the point I was getting at is that there is capital gains generally speaking on disposal of capital assets, but if you dispose of those assets then they're not "deemed" to be disposed of when you die, so you've avoided that problem at least. Capital gains is an issue in either country so no real net difference there although the rates are somewhat different.

The idea behind deemed dispositions is that you cannot avoid CGT through death or emigration, the US has a similar method of doing it for people who give up citizenship iirc.

Given that your residence is usually your principal asset that would be subject to CGT, but is exempt, and so are RRSPs and RRIFs, then it's not really a major issue for most Canadians.

Admittedly estate tax isn't either as you have to have a net worth of more than $5.25 million (or twice that if married).

No province though has an estate tax, but some States do.
In Canada, if you have significant capital gains on an asset, you either pay CGT when you sell/gift the asset, or your final income tax return (responsibility of the estate) has to include the CGT. Result = a hidden estate tax. Understood that most people's main asset, family home, is exempt. RRSPs, etc, aren't subject to capital gains tax but isn't there an income tax charge when they are drawn down?

In the U.S., if a person holds onto capital assets until death, then as far as I understand, any unrealized capital gains are not assessed to income. So this can be an effective tax planning strategy in the U.S. Especially for those whose estates are below the Federal estate tax threshold.
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Old May 23rd 2014, 6:44 am
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Default Re: US v. Canada on taxes

Well it's all about tax planning, it's just a different strategy. Most people in either country face no little or no tax on death. Canadians favour buying homes more than Americans apparently so the principle residence is exempt.

Investment strategy is quite an interesting topic because RRSPs are not subject to a penalty on early withdrawal, just income taxes, also the US treats short-term capital gains as income, Canada does not (or technically speaking all capital gains are treated as income but at a 50% valuation).

So yes, capital gains tax may apply in more situations than it does in the US but the rate can be significantly lower, depending on your investment strategy.

The strategy in Canada obviously is to dispose of everything that isn't exempt.
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Old May 25th 2014, 6:07 am
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Default Re: US v. Canada on taxes

Originally Posted by Steve_
Which I agreed with later on - but there's a massive difference in payroll taxes.



Not a fair comparison because I assume most don't and like I said there are a blizzard of pension schemes and whatnot to muddy the water. An RRSP doesn't have as many restrictions as a 401(k), for example.



Strangely we were just having this discussion in the Canada section and someone mentioned this website: http://www.numbeo.com/cost-of-living...&city2=Calgary

Although if you put in Baltimore, it's less.



Depends where you are, it's not consistent across either the US or Canada. In Alberta for example we only have 5% GST, but it applies to services and certain food items which are usually exempt in the US - but on the other hand, the rate is often higher than 5% in the US.



Toronto v. DC
This doesn't make sense to me. Sales taxes are much higher in Canada. Even ignoring that, beer, gas, electronic goods and a host of other things cost much more in Canada. That's why you hear about Canadians going to the US to shop in droves - not the other way around.

I spend a lot of time in Canada. My daughter lives in London, ON and I often go grocery shopping with her. The prices are just ridiculous compared to my local store. When I visit her, she asks me to bring up various products from my local pharmacy in the US such as vitamins, pain meds, first aid stuff, etc because it all costs so much more in Canada. I often shop at Best Buy and the London, ON store has much higher prices than my local store here in Maryland - again, that's even before the higher sales tax is added. So I regularly bring up Best Buy purchases for her as well. Same thing with IKEA, Target, etc. I'm struggling to think of a single thing that is cheaper in Canada. I've certainly never asked her to buy something for me in Canada because of lower cost!

Health care definitely costs me more in the US but then I don't have the access issues (e.g. referrals, waiting lists, provider choice, etc) that I would have in Canada. College tuition is higher in the US but my daughter is a Canadian citizen paying domestic tuition at Western. The other kids will go to "in state", public universities in the US if they don't go to college in Canada.

However, I also get a tax deduction on mortgage interest, property taxes, and college savings plans contributions. Finally, my salary in the US is much higher than it would be in Canada so, overall, I'm confident that I'm financially better off in the US.
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Old May 27th 2014, 11:48 am
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Default Re: US v. Canada on taxes

To be honest I thought the same thing but 681 contributors to that website apparently disagree with us!

It's not just about retail prices of a few things (and Best Buy is not competitive in Canada), it's also about rent, restaurants, etc. If you look at the list then fresh produce is listed as cheaper in Toronto. Rent and public transport are listed as being more in DC, that I believe.
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Old May 27th 2014, 12:24 pm
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Default Re: US v. Canada on taxes

Originally Posted by MarylandNed
Health care definitely costs me more in the US but then I don't have the access issues (e.g. referrals, waiting lists, provider choice, etc) that I would have in Canada. .
I have more choice of provider here for my GP then I ever did in the US where insurance company supplied me a list of doctors I could choose from.

Never had access issues, anytime a referral is needed, one has been done.

Now for now urgent/non-emergency issues, there have been waits, but I don't mind them, a small wait for something that isn't life threatening isn't an issue for me.

I've yet to experience any sort of wait when it was an emergency or very urgent health issue.

I'd change some wait times to paying a fortune for health insurance and possible end up bankrupt due to medical bills. You cannot assume you will always have the means or insurance to cover all future health issues.
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Old May 27th 2014, 3:26 pm
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Default Re: US v. Canada on taxes

Originally Posted by Jsmth321
I have more choice of provider here for my GP then I ever did in the US where insurance company supplied me a list of doctors I could choose from.
That depends on the health insurance company. Most allow you to go out of network and pay more for the privilege. I live in the DC area and have never needed to do that because of the wide choice of in network healthcare providers in this area.

Originally Posted by Jsmth321
Never had access issues, anytime a referral is needed, one has been done.
Yeah but it can be a pain and a waste of time. My plan does not require referrals at all so I can cut out the middle man and go straight to the specialist. Of course, abuse of this can drive up cost.

Originally Posted by Jsmth321
Now for now urgent/non-emergency issues, there have been waits, but I don't mind them, a small wait for something that isn't life threatening isn't an issue for me.
Except for the fact that the issue might be more urgent than you think or you might have the wrong diagnosis. Time can be critical in such situations.

Originally Posted by Jsmth321
I've yet to experience any sort of wait when it was an emergency or very urgent health issue.
Well, I have in Canada and I know plenty of other people who have too.

Originally Posted by Jsmth321
I'd change some wait times to paying a fortune for health insurance and possible end up bankrupt due to medical bills. You cannot assume you will always have the means or insurance to cover all future health issues.
That is definitely the biggest risk about the US system. I love the quality of US healthcare (if you have access to it) but I absolutely loathe the US health insurance system. To be honest, if I didn't have coverage, I'd probably move to Canada or the UK.
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