Canada–U.S. Retirement Plan Portability: Advanced Tax and Structuring Issues for Cross-Border Clients
Join Brian Wruk of Transition Financial Advisors Group as he will walk through advanced, real-world planning strategies for clients who move between Canada and the U.S.
Speakers

Ashley Murphy, CFP® GFP Fellow, is a tri-citizen of the USA, Australia and the UK. Ashley is the founder and Principal of Arete Wealth Strategists Australia, a fee-only financial planning and investment management firm for Australian/American expatriates in the United States and Australia.
From 2014 - 2017, Ashley taught in the CFP programs at UC Berkeley Extension and Golden Gate University. He served as a Knowledge Circle host for the Financial Planning Association's International and Cross-Border Knowledge Circle (2017 - 2019), and is a regular conference speaker. He holds a Graduate Diploma in Financial Planning in Australia making him one of the few financial advisors qualified in multiple countries. Ashley has been quoted in the Wall Street Journal and profiled in Financial Advisor Magazine.
Ashley lives with his wife Eliza, and daughters Elise & Jasmine in Minneapolis, MN. He enjoys cycling, reading and world travel. He is a futurist with interests in architecture, renewable energy and demographics.
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A dual Canadian/U.S. citizen, Brian holds both the U.S. and Canadian CFP® designations, is a Registered Trust and Estate Practitioner (TEP) with the Society of Trust and Estate Practitioners in the UK, holds the Canadian Investment Manager (CIM) designation and the RFP®designation from The Institute of Advanced Financial Planners. Based in the Phoenix, AZ area, Brian has written many articles on Canada/US Financial Planning, been quoted in numerous newspapers and journals in addition to speaking engagements but is most known as the author of two comprehensive books on Canada/US financial planning; The Canadian in America and The American in Canada.
Since January of 1997, Brian has worked specifically with American and Canadian residents moving between these two countries. Brian moved to Arizona in August 1990, to complete his MBA at the University of Arizona, moved back to Calgary with his US born spouse before moving permanently with his wife Kathleen to Arizona from Calgary in April of 1996.In addition to the CFP® designations and an MBA from The University of Arizona, Brian holds a Bachelor of Commerce degree from the University of Alberta, a Business Administration diploma from the Northern Alberta Institute of Technology (NAIT), and a Certified Advertising Agency Practitioner designation from the Institute of Canadian Advertising.
About this webinar
In this webinar, GFP Institute Fellow Brian Wruk of Transition Financial Advisors Group will walk through advanced, real-world planning strategies for clients who move between Canada and the U.S. — going beyond high-level checklists to explore the tricky planning, sequencing, and treaty mechanics that even experienced advisors sometimes get wrong.
Some of the relevant issues that will be addressed include:
- Treatment of RRSP/RRIF and commuted DB pensions for Canadians moving to the U.S., including TFSA/RESP pitfalls, PFIC landmines, and basis/timing mismatches on non-registered holdings
- Options for 401(k) and IRA accounts for Americans moving to Canada, including indirect 60(j) transfers to RRSP/RRIF and coordinating U.S. withholding, Canadian inclusion, and foreign tax credits
- Roth IRAs and Roth 401(k)s: how Canada views them, why they generally don't fit 60(j), and treaty-based strategies to preserve tax-free treatment
- Case studies where the "obvious" moves led to worse after-tax outcomes than a more nuanced treaty-driven approach
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