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Canada vs. U.S.: A Side-by-Side Guide to Retirement

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Fact checked by Suzanne KvilhaugReviewed by Anthony BattleFact checked by Suzanne KvilhaugReviewed by Anthony Battle

Retirement in Canada vs. the U.S.: An Overview

The American and Canadian governments provide many of the same types of services for people who have reached retirement age. However, Canada has a more generous retirement system.

The poverty rate for Canadians over age 65 was 4.7%, according to Canada’s latest census. That’s lower than any other age group in the country and half the poverty rate for U.S. citizens of the same age. American retirees may need ways to supplement their retirement incomes due to their lower incomes and the risk of running out of money.

Key Takeaways

  • The Canadian Registered Retirement Savings Plans and the Tax-Free Savings Account are similar to U.S. traditional and Roth IRAs.
  • Canadian retirement accounts have more generous contribution limits and fewer distribution limits than American accounts.
  • Old Age Security (OAS), one of the three types of pension plans in Canada, is funded by general tax revenues, unlike Social Security in the U.S.
  • The Canada Pension Plan is funded by payroll taxes, much like Social Security in the U.S.
  • Canada’s single-payer health insurance is available to citizens throughout their lives.
  • America’s Medicare is eligible only to those 65 or older and it covers a lower percentage of medical costs.

A major benefit for Canadians is the publicly-funded universal health care system, which provides them with essential medical services throughout their lives, as well as in retirement. It has no copays or deductibles.

In contrast, Americans have no single-payer insurance unless they’re disabled or extremely low-income until they reach age 65, when they can qualify for Medicare. Medicare doesn’t cover most vision, dental, or hearing care costs. About one in five Medicare recipients reported paying more than $2,000 in out-of-pocket expenses, according to a Commonwealth Fund study.

A study by the Employee Benefit Research Institute estimated that some retired couples with particularly high prescription drug costs will need approximately $413,000 to comfortably afford Medicare premiums and out-of-pocket medical expenses in retirement.

Retirement Savings Plans in the U.S. vs. Canada

Canada and America both offer individuals similar retirement financial vehicles with similar tax advantages.

Contribution Limits: RRSP vs. Traditional IRA and 401(k)

Registered Retirement Savings Plans (RRSPs) allow investors to receive a tax deduction on their yearly RRSP contributions in Canada. Money invested in the plan grows tax-deferred and this advances the benefits of compounded returns. Contributions can be made until the age of 71 and the government sets maximum limits on the amount that can be placed into an RRSP account: 18% of a worker’s pay up to CA$31,560 in 2024 (CA$30,780 in 2023).

Investors can contribute more but additional sums over $2,000 will be hit with penalties.

Traditional IRAs

Traditional individual retirement account (IRA) contributions in the United States are more limited than their Canadian counterpart. The Internal Revenue Service (IRS) has set the maximum contribution for traditional IRAs at $7,000 per year for 2024 or the amount of your taxable compensation for the taxable year, whichever is less. People age 50 or older can sock away an additional $1,000 per year in 2024 as a catch-up contribution.

IRAs carry a 10% tax penalty if funds are withdrawn before the taxpayer reaches the age of 59½, but there’s a special exemption at the age of 55 called the 72(t) that allows distributions without penalty.

Defined Contribution Plans

Defined contribution plans include American 401(k) plans offered through an employer. They’re more comparable to RRSPs. The annual contribution limit for 2024 is $23,000, and those aged 50 or older can contribute an additional $7,500 per year for a total of $30,500.

Withdrawals and Taxes

Withdrawals from an RRSP can occur at any time but are classified as taxable income subject to withholding taxes. The RRSP must be either cashed out, used to purchase an annuity, or transferred into a Registered Retirement Income Fund (RRIF) in the year in which the taxpayer reaches age 71.

Traditional IRAs and 401(k)s are structured to provide the same sorts of benefits to American taxpayers. Contributions reduce taxable income, and capital gains are tax-deferred. However, withdrawals or distributions are taxed at the individual’s income tax rate.

Canada’s TFSA vs. America’s Roth IRA

Canada’s Tax-Free Savings Account (TFSA) is similar to the Roth IRA in the United States. Both of these retirement-focused vehicles are funded with after-tax money. There’s no tax break in the year of the contribution, but both accounts offer tax-free earnings growth, and withdrawals are not taxed, subject to certain rules.

Contribution Limits for TFSAs and Roth IRAs

Canadian residents over the age of 18 can contribute up to CA$7,000 to TFSAs in 2024.

The annual maximum contribution to a Roth IRA is $7,000 for 2024 or $8,000, with the $1,000 catch-up contribution for those age 50 or older. There’s no limit on when one must stop making contributions and begin withdrawing money with either of these accounts.

Advantages of TFSAs Over Roth IRAs

TFSAs offer two significant advantages over Roth IRAs. Young Canadians saving for retirement can carry over their contributions to future years, but such an option isn’t available with Roth IRAs. If a taxpayer has reached age 35 and is unable to contribute CA$7,000 into their account due to an unforeseen outlay, the total allowable amount accumulates to CA$14,000 in the next year.

The contribution limits have changed year-to-year since the TFSA was first introduced in 2009. The limit sometimes sets at different ranges between $5,000 and $10,000. The cumulative limit for 2024 is CA$95,000.

Sums equivalent to contributions can be withdrawn at any time but distributions of earnings out of Roth IRAs must be classified as “qualified” to avoid taxes. Qualified distributions are those made after the account has been open for five years and the taxpayer is either disabled or at least age 59½.

Government Pensions in the U.S. vs. Canada

Both the United States and Canada provide workers with a guaranteed income when they reach retirement age, but these federal pension plans differ from each other in several ways.

Canada’s Old Age Security

Canada has a three-part system:

  1. Old Age Security (OAS), financed by Canadian tax dollars, provides benefits to eligible Canadians who are at least 65 years of age.
  2. The Canada Pension Plan (CPP) is funded by payroll deductions, like Social Security in the United States. It makes benefits available as early as age 60.
  3. The Guaranteed Income Supplement (GIS) is available to Canadians with the fewest resources.

OAS provides benefits to eligible citizens who have reached age 65. Complex rules determine the amount of the pension payment, but an individual who has lived in Canada for 40 years after turning 18 is typically qualified to receive the full payment. As of 2024, the full payment is CA$718.33 per month from the age of 65 to 74 and CA$790.16 when they reach age 75.

The OAS implements a clawback provision known as the OAS recovery or repayment. High-income earners over the age of 65 are required to repay some or all of the OAS pension. This clawback is adjusted annually for inflation and varies by reported income.

OAS beneficiaries who choose to delay receiving benefits can get higher payouts, much like with Social Security. Benefits can be delayed for up to five years up to age 70. OAS benefits are taxable income.

Important

Canada imposes higher income taxes on its citizens than the United States does on its residents to subsidize universal health care and pensions.

Social Security

American Social Security benefits don’t focus exclusively on providing retirement income. They encompass additional assistance, including disability income, survivor benefits, and Medicare (to the extent that Medicare premiums are taken out of Social Security benefits).

Social Security income tax issues are slightly more complex and depend on factors such as the recipient’s marital status and whether income was generated from other sources. Information provided in the IRS Form SSA-1099 will determine the tax rate for the benefit.

Note

Canada’s retirement programs are generally considered safe because they’re funded out of general tax revenues. There have been fears that the United States Social Security system, which is instead funded through payroll taxes on employee wages, will become underfunded.

Individuals are eligible to receive partial benefits when they reach age 62 and full benefits when they reach age 66 or 67, depending on their year of birth.

Eligibility is determined through a credit system. Qualified recipients must obtain a minimum of 40 credits. They can earn additional credits to increase their payments by delaying initial benefit payments up to age 70.

Can a Canadian Retire Full Time in the U.S.?

A Canadian citizen cannot retire full-time in the U.S. without going through the proper immigration channels. There are ways that a Canadian can retire part-time in the U.S., however, because they’re legally permitted to spend six months a year in the U.S. without needing visas/permits.

Can You Collect U.S. Social Security in Canada?

Yes, a U.S. citizen can collect Social Security benefits if they live in Canada or anywhere else outside of the U.S. other than a small number of restricted countries as long as they’re eligible for Social Security.

Does Canada Tax U.S. Retirement Income?

Yes, Canada taxes U.S. retirement income, but Social Security is only taxed in the country of residence. That income will be taxed in Canada, not the U.S., if you receive U.S. Social Security income and live in Canada. U.S. pension income will be taxed in both the U.S. and Canada but the U.S. portion is available as a foreign tax credit in Canada.

The Bottom Line

The American and Canadian systems provide many similar benefits to retirees with similar types of tax-advantaged accounts that allow people to save for retirement. But Canadian retirees enjoy a lower poverty rate than those on the other side of the border.

Read the original article on Investopedia.

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