RRSP/RRIF Withdrawal Tax for US Residents (Treaty)
Living in the US with a Canadian RRSP or RRIF? Canada withholds tax when you draw it down. This estimates the 25% rate on a lump-sum or non-periodic payment versus the 15% Canada-US treaty cap on periodic RRIF payments, and runs the CRA periodic-payment test that decides which rate you get.
What you keep vs what Canada withholds
Net to you and Canadian withholding at each rate.
Periodic-payment test
The CRA test that decides whether your RRIF payment gets the 15% treaty cap or the 25% default.
| Line item | Amount |
|---|
How this is calculated
1. Default rate — 25% (Part XIII)
Any RRSP or RRIF amount paid to a non-resident is subject to 25% Canadian non-resident withholding tax under the Income Tax Act s.212(1). This is the starting point for every payment. Source: Income Tax Act (Canada) s.212(1).
2. Treaty cap — 15% on periodic pensions
Article XVIII(2)(a) of the Canada-US tax treaty limits Canadian tax on a periodic pension payment to a US resident to 15% of the gross amount. This reduces the 25% domestic rate but only for qualifying periodic payments. Source: Canada-US Tax Convention, Article XVIII, confirmed by IRS Publication 597.
3. Lump sums get no reduction
Lump-sum RRSP collapses and non-periodic payments are excluded from the definition of "periodic pension payment," so they stay at 25%. Source: Income Tax Conventions Interpretation Act s.5.
4. The CRA periodic-payment test
A RRIF payment counts as periodic (and gets 15%) only if the total payments in the calendar year do not exceed the greater of: (a) 2 × the RRIF minimum amount for the year, and (b) 10% of the fund's fair market value at January 1. Draw more than that and the whole payment reverts to 25%. Source: ITCIA s.5, CRA External T.I. 9333995 & 9526965.
5. The RRIF minimum amount
Under 71: minimum = January-1 value ÷ (90 − age at Jan 1). Age 71+: minimum = January-1 value × the prescribed factor (5.28% at 71, 5.40% at 72, rising to 20% at 95+). Source: CRA "Minimum amount from a RRIF", Income Tax Regulations s.7308.
6. The US side (not modelled in the dollars)
The distribution is also taxable on your US return as ordinary income, though a US person generally has cost basis equal to non-deductible contributions, so only the growth is taxed there. The Canadian tax withheld is generally creditable against US tax as a foreign tax credit (Form 1116, treaty Article XXIV). Rev. Proc. 2014-55 governs the US treaty deferral and ended the old Form 8891 filing. Source: IRS Publication 597.
What this does not model
Whether you actually qualify as a US resident / treaty beneficial owner or have a departure-tax issue; the exact US taxable portion (the return-of-basis split is fact-specific); your net US tax after the foreign tax credit or any FTC limitation; US state tax (several states ignore the treaty and tax RRSP/RRIF in full with no credit); the first-year-RRIF nil-minimum interaction with the test; an NR7-R refund of over-withholding; and any currency/FX-timing or provincial effects. The minimum-factor table and the periodic-payment test are administrative positions — the payer or your advisor confirms the actual rate on your T4RIF / NR4.
Common questions
How much Canadian tax is withheld on an RRSP withdrawal for a US resident?
A lump-sum or non-periodic RRSP or RRIF payment to a non-resident is subject to 25% Canadian non-resident (Part XIII) withholding tax. Ordinary RRSP withdrawals do not qualify for any treaty reduction, so 25% applies. The Canada-US treaty only lowers the rate to 15% for payments that count as a periodic pension payment, which generally means a RRIF, not an RRSP.
When does the Canada-US treaty reduce RRIF withholding to 15%?
Article XVIII(2)(a) of the Canada-US treaty caps Canadian tax on a periodic pension payment at 15%. The CRA treats a RRIF payment as periodic up to the greater of (a) twice the RRIF minimum amount for the year, and (b) 10% of the fund's fair market value at January 1. If your annual payments exceed that threshold, only the portion above it is withheld at 25% — the amount up to the threshold still gets the 15% treaty cap, so the effective rate is a blend, not a flat 25% on the whole payment.
How is the RRIF minimum amount calculated?
For a RRIF holder under 71, the minimum amount is the January 1 fair market value divided by (90 minus the age at January 1). At age 71 and older, a prescribed factor table applies (for example 5.28% at 71, 5.40% at 72, rising to 20% at 95 and older). The minimum amount is that factor multiplied by the January 1 value.
Do US residents pay US tax on RRSP or RRIF withdrawals too?
Yes. The distribution is also taxable on the US return as ordinary income, though a US person generally has cost basis equal to non-deductible contributions, so only the growth portion is taxed on the US side. The Canadian tax withheld is generally creditable against US tax as a foreign tax credit (Form 1116). Some US states do not follow the treaty and tax the full amount with no credit, so confirm your situation with a cross-border tax professional.