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:

Passport to Wealth is a proud member of the SwissCast Network

Discover more podcasts for English-speaking Switzerland

SwissCast Network

www.passporttowealth.com

www.passporttowealth.com

Americans Moving to Canada in 2026: Taxes, Healthcare and Money

Passport To Wealth®

Americans Moving to Canada in 2026: Taxes, Healthcare and Money