Snowbirds US Expats Radio Podcast

Gerry Scott

Whether you're a Canadian snowbird spending winters in the USA, or an American looking to move to Canada, the Snowbirds Expats Radio Podcast is loaded with useful information to guide you. Gerry Scott is the host of this podcast, Monday to Friday, Gerry works with Canadian and US clients as a cross border advisor with one of Canada’s largest and most respected wealth management firms.. The Snowbirds Expats Radio Podcast is brought to you by the Snowbirds US Day Tracker and the Canada Physical Presence Tracker apps. The Snowbirds US Day Tracker app helps you track the number of days you’re spending in the USA, which is essential to avoid being classified by the IRS as a US resident for tax purposes. The Canada Physical Presence Tracker is the easiest and most reliable way to track your physical permanent days for the purpose of renewing your permanent residence card (maple card). Simply enter the days into the calculator and track the progress as you get closer and closer to becoming a full time resident of Canada. Both apps offer a wide variety of services that include, USD exchange, tax and legal services, Real Estate, Medical Tourism, and more. Download them today on your iPhone or Android.

  1. Sep 22

    Episode 96: The Great Return: The Tax Traps Waiting for Canadians Moving Back Home

    Guest: Pat Fournier, JPS Accounting Services (Port Coquitlam, BC) You've decided to move back to Canada. You think the hard part is over. Gerry sits down with cross-border accountant Pat Fournier of JPS Accounting Services to walk through Chapter 2 of The Great Return, and the message is clear: leaving the US isn't something that just happens when you cross the border. It's something you have to prove, on paper, to two different tax authorities that don't talk to each other and won't figure it out for you. Pat has seen the mistakes up close, from Canadians who used a BC mailing address to open an investment account while still living full-time in the US, to returning residents who assumed their first year back gave them a free pass on foreign reporting. She and Gerry cover what actually triggers IRS and CRA recognition of a move, what happens to IRAs, 401(k)s, and Roth accounts when you cross the border, and why the T1135 form catches so many people off guard. What You'll Learn There's no punch card for leaving the US. The IRS doesn't automatically know you've gone. Green card holders who surrender their card need to file the appropriate form, and until it's filed, you're still considered a resident with ongoing filing obligations. CRA looks at the facts, not a date you pick. Car insurance, family location, a house purchase, where you're really living, all of it factors into when CRA decides your Canadian residency actually started. The Canadian address mistake. Using a Canadian mailing address to open an investment account while still living in the US can trigger CRA to treat you as a resident and tax your full worldwide income, long before you meant to make that move. The Roth IRA election most people miss. A Roth is tax-free in the US, but that status doesn't carry over automatically. Without filing an election letter with CRA in your first year back, Canada will tax the account's growth. Late elections are possible but not guaranteed. The IRA-to-RRSP "rollover" isn't really a rollover. Moving IRA or 401(k) funds into an RRSP means cashing out and facing US tax first. Pat explains why you need liquid cash on hand to cover the gap, and why some Canadian advisors push this move without fully weighing the cost. Social Security gets taxed differently than people expect. Once you're a Canadian resident, Canada taxes your US Social Security, not the IRS, per the treaty. Pat's advice: stop any voluntary US withholding before you move. The T1135 trap for returning Canadians. New immigrants to Canada get a one-year exemption from this foreign reporting form. Returning Canadians do not. It also covers more than the US equivalent (FBAR), including rental properties, and its reporting threshold is based on cost, not current value. RRSP contribution room doesn't show up on day one. Room is based on the prior year's Canadian earned income, so most people have zero room their first year back unless they're using carryforward room from before they left. Give yourself at least three months. Pat's rule of thumb for how much lead time to build into your planning before an actual move date. Resources & Links Guest: Pat Fournier, JPS Accounting Services, Port Coquitlam, BC Book: The Great Return: Canadians' Guide to Moving Home from the US — Chapter 2 sample now available on Amazon Snowbirds US Day Tracker letsmovetocanada.ca

    Episode 96: The Great Return: The Tax Traps Waiting for Canadians Moving Back Home
  2. Sep 8

    Episode 95: What Canadian Green Card Holders Need to Know Before They Surrender Status

    Guest: Robert Clegg, CanadAmerican Tax Services Host: Gerry Scott Episode Overview A lot of Canadians who built a life in the United States assume that walking away from a green card is as simple as handing it back at the border. It is not. In this episode, Gerry sits down with cross-border tax specialist Robert Clegg of CanadAmerican Tax Services to unpack the U.S. Exit Tax, the rule that can turn a routine move back to Canada into a six-figure tax bill. Robert walks through how the IRS decides who counts as a covered expat, why the 8-out-of-15-year rule catches long-term green card holders off guard, and what really happens at the border when an officer decides your green card has been abandoned. Real client scenarios, including a near miss at the seven-year mark, illustrate just how much timing matters. Whether you are holding onto a green card out of habit, weighing citizenship, or planning your eventual return to Canada, this conversation lays out exactly what to check before you make a move. What You'll Learn What the U.S. Exit Tax actually is, and how it mirrors Canada's departure tax with a mark-to-market calculation on the day you renounce or abandon status The $2 million net worth threshold that determines whether you're a covered expat, and the roughly $800,000 exclusion available against any deemed gain Why deferred compensation, including 401(k)s and RRSPs, faces a 30 percent withholding if you're a covered expat, and why CPP, OAS, and Social Security are treated differently The 8-out-of-15-year rule for green card holders, including how even one day of residency in a given year counts toward the eight Why a green card does not simply expire after ten years for tax purposes, and the official abandonment process required to stop U.S. filing obligations How border officers assess whether you've abandoned your green card by living in Canada, and what filing a Canadian tax return as a resident signals What a reentry permit is and how it protects green card holders who plan to spend up to two years outside the U.S. without losing status Why there's no do-over once a green card is surrendered, and the limited exceptions for U.S. citizen spouses or children The case for taking U.S. citizenship before moving back to Canada if you ever want unrestricted reentry, including the Medicare timing consideration for retirees under 65 Practical consequences of renouncing, from B-2 visitor day limits to firearm import restrictions to how a Canadian DUI or criminal record can bar reentry for former citizens Resources & Links Guest: Robert Clegg, CanadAmerican Tax Services — cross-border personal, corporate, and partnership tax planning IRS Form 8854, Initial and Annual Expatriation Statement USCIS Form I-131, Application for Travel Document (includes the reentry permit for green card holders) USCIS naturalization eligibility tool snowbirdsheadingsouth.com This episode is for educational purposes only and does not constitute individualized tax, legal, or financial advice. Listeners should consult a qualified cross-border accountant, tax attorney, or financial advisor before making decisions about green card abandonment, U.S. citizenship, or a cross-border move.

    Episode 95: What Canadian Green Card Holders Need to Know Before They Surrender Status
  3. Aug 25

    Episode 94: Why Vancouver Island: Choosing Where to Land When You Move Back to Canada

    Gerry sits down with Denise Hodgins, a REALTOR® with eXp Realty who specializes in lifestyle-driven moves to Vancouver Island. Together they dig into why Nanoose Bay, Parksville and Qualicum Beach have become such a draw for Canadians heading home and Americans relocating north, and they unpack two of the biggest financial landmines buyers need to understand before they fall in love with a listing: the foreign buyer ban and the speculation and vacancy tax. What They Discussed Denise's background and her focus on lifestyle-driven real estate moves across Vancouver Island Canada's foreign buyer ban, set to expire January 1, 2027, and why industry analysts don't expect lifting it to move affordability much Why Vancouver Island keeps winning people over: pace of life, beach access, year-round golf, and a housing market that still offers relative value The speculation and vacancy tax, which areas are currently exempt (Nanaimo, Lantzville, Parksville, Qualicum, Nanoose, French Creek, Errington, Coombs, Bowser, Deep Bay), and why exemption boundaries can be easy to misread What the tax actually costs: potentially $45,000+ annually for foreign owners, with different rates for Canadian citizens and permanent residents Why buyers need a full cross-border team in place before they fall in love with a house: REALTOR®, immigration lawyer, cross-border tax accountant, and cross-border financial advisor A cautionary story about a client who trusted a charming but unqualified advisor, and what it cost to clean up afterward FIRPTA withholding on the sale of US property, and why the IRS holds back a portion of proceeds until you prove you don't owe tax A tour of Nanoose Bay's Fairwinds community: golf course, wellness centre, marina, and the new Pheasant Glen clubhouse coming this fall Trails and biking in the area, plus planned expansions connecting Top Ridge Park to Coombs Links & Resources Connect with Denise: https://www.bcislandhomes.ca/ The Great Return: Canadian's Guide to Moving Home from the US — letsmovetocanada.ca Canadians Heading South for the Winters — snowbirdsheadingsouth.com Track your cross-border travel days — snowbirdsusdaytracker.com

    Episode 94: Why Vancouver Island: Choosing Where to Land When You Move Back to Canada
  4. Aug 12

    Lost Canadians, Legal Realities: What Accidental Citizenship Actually Means for Your Move

    Most people treat a Canadian-born grandparent as fun family trivia, not a legal pathway to citizenship. But thanks to a change in Canadian law, that old birth certificate could now be the key to citizenship, residency, and a new set of cross-border tax questions. That's the reality cross-border attorney Robert Clegg sees again and again, and it's what he unpacks in this episode. Robert returns from Victoria, BC to talk with Gerry about Canada's expanded "Lost Canadian" citizenship rules. Robert is a U.S. immigration and tax attorney based in Seattle and Victoria with 30+ years of cross-border experience. They dig into who qualifies, how to apply, and the realities of relocating to Vancouver Island. What You'll Learn: The Dec. 2025 rule change: citizenship now extends to grandchildren and great-grandchildren of Canadian-born ancestors.A real case study: how one American traced citizenship through his Alberta-born grandfather.Why 3-4 million Americans may be eligible, with 150,000+ applications filed and ~1 year wait times.Why dual citizenship is required before renouncing U.S. citizenship.How the BC Speculation and Vacancy Tax ties to citizenship status.Popular Vancouver Island landing spots: Victoria, Qualicum Beach, Cobble Hill, Nanaimo, Sydney.Why most renunciations happen after 5-50 years in Canada, not for political reasons.Why the ~$13M U.S. estate tax exclusion means most clients aren't exposed.The overlooked hurdle of rebuilding credit and banking across the border.

    Lost Canadians, Legal Realities: What Accidental Citizenship Actually Means for Your Move
  5. Jul 28

    Episode 92: The Great Return — Gerry’s New Book on Moving Home from the US

    Guest Host: Laura Garfield | Co-Founder, Idea Decanter  |  Guest: Gerry Scott You spent years building a life in the US - a green card, a career, maybe even citizenship. So what happens to your taxes, your investments, and your retirement accounts the moment you decide to move back home to Canada? The tables are turned this episode: Laura Garfield, co-founder of Idea Decanter, steps in as host to interview Gerry Scott about his brand new book, The Great Return: Canadian's Guide to Moving Home from the US. It's the companion to Gerry's first book, Canadians Heading South for the Winters, and this time it's written for the reverse journey - Canadians coming home after years in the US, and Americans making the move north. Gerry and Laura get into why this move feels deceptively easy (same language, similar culture) when in reality it means untangling two completely different tax systems, the CRA and the IRS. They cover exit tax and the difference between a covered and non-covered expat, why cross-border financial advisors can't legally follow clients across the border, and why DIY moves so often lead to expensive mistakes. Laura also shares her own cross-Canada train trip, and Gerry brings up the Lost Canadians genealogy angle for Americans who may already qualify for Canadian citizenship. What You'll Learn Who The Great Return was written for, and why it applies to Americans moving to Canada too Why the CRA and IRS don't line up, even though crossing the border barely feels like leaving home The difference between a covered and non-covered expat, and why it matters for exit tax Why US states like California and Hawaii don't recognize the Canada-US tax treaty Why your US financial advisor can't legally advise you once you move to Canada What happens tax-wise to Roth contributions, employee stock purchase plans, and pensions after the move How the Lost Canadians genealogy path could mean Americans already qualify for citizenship Resources & Links The Great Return: Canadian's Guide to Moving Home from the US — letsmovetocanada.ca Canadians Heading South for the Winters — snowbirdsheadingsouth.com Snowbirds US DayTracker — snowbirdsusdaytracker.com

    Episode 92: The Great Return — Gerry’s New Book on Moving Home from the US
  6. Jul 14

    Episode: 91 Cross-Border Death and Taxes: Estate Planning for Canadians with US Assets

    Nobody wants to think about what happens to their Florida condo or Arizona snowbird home after they're gone. But if you're a Canadian with US property and you haven't planned for it, your family could be facing an audit, a probate mess, and tax consequences that were entirely avoidable. That's the reality cross-border tax attorney Alexey Manasuev sees again and again in his practice, and it's exactly what he unpacks in this episode. Alexey returns to the show from Tampa Bay to talk with Gerry about cross-border estate and tax planning for Canadian snowbirds. Alexey is a US tax attorney admitted in New York and DC, and the founder of US Tax IQ, a boutique firm focused exclusively on US international tax planning, compliance, and structuring. Together, Gerry and Alexey dig into what really happens when a Canadian passes away owning US real estate without a plan in place, and how to make sure that doesn't happen to you. What You'll Learn in This Episode Why proactive planning matters: Alexey explains how problems with US property often surface only after death, when probate alerts the IRS to gaps left decades earlier, turning what should have been a non-issue into an audit. US estate tax exposure for Canadian-owned property: how a Florida, Arizona, or other US property can trigger US estate and gift tax obligations for a Canadian owner, even without US citizenship or residency. Domicile vs. residency: why US estate and gift tax exposure is based on the legal concept of domicile, a facts-and-circumstances test built around intent, not the same as ordinary tax residency. The LLC trap: why an LLC structure that a local US advisor recommends for domestic buyers can create serious problems for Canadian owners on both sides of the border. One will or two: when a single will can work for a cross-border estate, and why a US power of attorney for incapacity and medical decisions is often more important than a second will. The 2026 estate tax exemption threshold: how the $15 million federal base exclusion amount taking effect in 2026 factors into planning decisions. Sell now or hold for the next generation: the shifting trend Alexey is seeing, with some families selling US property as they age while others hold on for the lifestyle and pass it down. Why "campfire advice" is dangerous: why casual, well-meaning tips from friends, neighbors, or a local advisor unfamiliar with cross-border rules can create costly problems, and why a paid consultation with a qualified cross-border tax professional pays for itself. Resources and Links US Tax IQ Snowbirds US Day Tracker App Canadians Heading South for the Winters: What You Don't Know Will Hurt You, by Gerry Scott

    Episode: 91 Cross-Border Death and Taxes: Estate Planning for Canadians with US Assets
  7. Jun 30

    Episode 90: You Might Already Be Canadian and Not Know It

    If you have a Canadian ancestor somewhere in your family tree, you might not need to look very far back. A landmark change to Canadian citizenship law means that for millions of people, especially Americans, that ancestry could now open the door to a Canadian passport. And the person who can help you find that door is a genealogist. This week Gerry sits down with Sheila Hobeck, professional genealogist and founder of Kinalytic, based in Oakville, Ontario, to walk through what Bill C-3 actually means, how to document your Canadian lineage, and why DNA is rewriting family histories that paper records tried to keep buried. What You'll Learn in This Episode What Bill C-3 actually changes: effective December 2025, Canada eliminated the generational limit on citizenship by descent, meaning a Canadian ancestor anywhere in your history, if you can document it, may be enough to claim Canadian citizenshipWho counts as a lost Canadian and why historical acts stripped citizenship from individuals through marriage, birth abroad, and other circumstances that Bill C-3 now addressesHow to start the process through IRCC, when to bring in a Regulated Canadian Immigration Consultant, and when the situation calls for an immigration lawyerWhere genealogists search, from Ancestry and FamilySearch to physical archives and historical societies, and why not everything has been digitizedThe role of DNA in confirming lineage, identifying unknown relatives, and uncovering what Sheila calls NPEs, non-paternity events, where documents and biology don't matchHow AI is helping translate old records written in Quebec French, Latin, and paleographic script, and point researchers toward the right archivesWhy this matters beyond immigration, and what your ancestors' risks and journeys reveal once you start diggingResources and Links Sheila Hobeck, Kinalytic: kinalytic.comIRCC, Immigration, Refugees and Citizenship Canada: canada.ca/en/immigration-refugees-citizenshipFamilySearch (free): familysearch.orgAncestry: ancestry.caGEDmatch: gedmatch.comFamilyTreeDNA: familytreedna.comTrack your days across the border with DayTracker: snowbirdsusdaytracker.comCanadians Heading South - Buy the Book: snowbirdsheadingsouth.com

    Episode 90: You Might Already Be Canadian and Not Know It
  8. Jun 16

    Episode 89: The U.S. Exit Tax and the 8-Out-of-15-Year Rule

    What Canadian Green Card Holders Need to Know Before They Surrender Status Guest: Robert Clegg, CanadAmerican Tax Services  |  Host: Gerry Scott Episode Overview A lot of Canadians who built a life in the United States assume that walking away from a green card is as simple as handing it back at the border. It is not. In this episode, Gerry sits down with cross-border tax specialist Robert Clegg of CanadAmerican Tax Services to unpack the U.S. Exit Tax, the rule that can turn a routine move back to Canada into a six-figure tax bill. Robert walks through how the IRS decides who counts as a covered expat, why the 8-out-of-15-year rule catches long-term green card holders off guard, and what really happens at the border when an officer decides your green card has been abandoned. Real client scenarios, including a near miss at the seven-year mark, illustrate just how much timing matters. Whether you are holding onto a green card out of habit, weighing citizenship, or planning your eventual return to Canada, this conversation lays out exactly what to check before you make a move. What You'll Learn What the U.S. Exit Tax actually is, and how it mirrors Canada's departure tax with a mark-to-market calculation on the day you renounce or abandon status The $2 million net worth threshold that determines whether you're a covered expat, and the roughly $800,000 exclusion available against any deemed gain Why deferred compensation, including 401(k)s and RRSPs, faces a 30 percent withholding if you're a covered expat, and why CPP, OAS, and Social Security are treated differently The 8-out-of-15-year rule for green card holders, including how even one day of residency in a given year counts toward the eight Why a green card does not simply expire after ten years for tax purposes, and the official abandonment process required to stop U.S. filing obligations How border officers assess whether you've abandoned your green card by living in Canada, and what filing a Canadian tax return as a resident signals What a reentry permit is and how it protects green card holders who plan to spend up to two years outside the U.S. without losing status Why there's no do-over once a green card is surrendered, and the limited exceptions for U.S. citizen spouses or children The case for taking U.S. citizenship before moving back to Canada if you ever want unrestricted reentry, including the Medicare timing consideration for retirees under 65 Practical consequences of renouncing, from B-2 visitor day limits to firearm import restrictions to how a Canadian DUI or criminal record can bar reentry for former citizens Resources & Links Guest: Robert Clegg, CanadAmerican Tax Services - cross-border personal, corporate, and partnership tax planning https://www.canadamericantax.com/meet-us.php IRS Form 8854, Initial and Annual Expatriation Statement: https://www.irs.gov/forms-pubs/about-form-8854 USCIS Form I-131, Application for Travel Document (includes the reentry permit for green card holders): https://www.uscis.gov/i-131 USCIS naturalization eligibility tool: https://www.uscis.gov/citizenship snowbirdsheadingsouth.com

    Episode 89: The U.S. Exit Tax and the 8-Out-of-15-Year Rule

About

Whether you're a Canadian snowbird spending winters in the USA, or an American looking to move to Canada, the Snowbirds Expats Radio Podcast is loaded with useful information to guide you. Gerry Scott is the host of this podcast, Monday to Friday, Gerry works with Canadian and US clients as a cross border advisor with one of Canada’s largest and most respected wealth management firms.. The Snowbirds Expats Radio Podcast is brought to you by the Snowbirds US Day Tracker and the Canada Physical Presence Tracker apps. The Snowbirds US Day Tracker app helps you track the number of days you’re spending in the USA, which is essential to avoid being classified by the IRS as a US resident for tax purposes. The Canada Physical Presence Tracker is the easiest and most reliable way to track your physical permanent days for the purpose of renewing your permanent residence card (maple card). Simply enter the days into the calculator and track the progress as you get closer and closer to becoming a full time resident of Canada. Both apps offer a wide variety of services that include, USD exchange, tax and legal services, Real Estate, Medical Tourism, and more. Download them today on your iPhone or Android.

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