Julia VachonSon Heung-min is back in the headlines in the summer of 2026, a year on from the move that stunned world football: the former Tottenham captain swapped the Premier League for Major League Soccer, joining Los Angeles FC as a Designated Player in a deal widely reported as a club-record transfer. For Canadian fans following his LAFC form this season, the story is a sporting one. For anyone who has ever thought about moving between Canada and the United States for work, it is also a case study in one of the most under-appreciated financial risks there is: cross-border taxation.
Son's relocation is an extreme, high-net-worth version of a decision thousands of Canadians make every year. The mechanics that apply to a footballer earning a designated-player salary in California apply, in miniature, to a software engineer taking a job in Seattle or a nurse crossing to Detroit. The dollar figures differ. The rules do not.
What actually happens when you leave Canada
The moment that matters is not the day you land in your new country. It is the day you become a non-resident of Canada for tax purposes — the date you sever your primary residential ties, such as a home and a resident spouse or dependants. On that date, the Canada Revenue Agency treats you as having sold most of your property at fair market value and immediately reacquired it. This is the so-called "departure tax," a deemed disposition that can trigger capital gains on assets you have not actually sold.
Not everything is caught. Canadian real estate, registered plans such as RRSPs and TFSAs, and certain pension rights are generally excluded from the deemed disposition. But an investment portfolio, shares in a private company, or a stock-option position can generate a real tax bill in the year you leave, on paper gains you never converted to cash. A departing athlete with image-rights companies and an equity portfolio faces exactly this problem at scale.
For an ordinary emigrant, the CRA's guidance on leaving Canada as an emigrant sets out how residency status, the departure-tax calculation, and the option to defer payment on the deemed gain all work. It is dense reading, and the exclusions are precisely where mistakes happen.
Two countries, one salary
Once you are working in the United States, the second problem appears: you are potentially taxable in both countries on the same income. The Canada–United States tax treaty exists to prevent that double taxation, but it does not do so automatically. Relief comes through foreign tax credits, treaty tie-breaker rules that assign residency to one country, and careful timing of when income is recognized.
The United States adds a wrinkle that trips up almost every newcomer: it taxes on the basis of citizenship and residency, and its reporting requirements for foreign accounts are aggressive. A Canadian who keeps an RRSP, a TFSA, or a Canadian brokerage account after moving south can face US filing obligations on those accounts. The TFSA in particular is a trap — prized as tax-free in Canada, it is generally not recognized as tax-sheltered by the US, and can create reporting headaches that outweigh its benefit for a US resident.
Why this is a job for a professional, not a spreadsheet
The temptation is to treat a cross-border move as an administrative task. It is not. The interaction between two tax systems, a bilateral treaty, provincial rules, and the timing of a departure date creates a planning window that closes the day you leave. Decisions made before departure — realizing or deferring gains, restructuring accounts, choosing an emigration date — are far cheaper than fixes attempted afterward.
A qualified cross-border tax advisor or a wealth manager with international expertise can map the specific ties that determine your residency date, model the departure-tax exposure, and coordinate filings on both sides of the border so the same dollar is not taxed twice. For higher earners the stakes are obvious, but the percentage cost of getting it wrong is often heaviest for middle-income movers who assume the treaty handles everything for them.
If you are weighing a move to the US and want to understand your exposure before you commit, this is exactly the kind of situation where a consultation with a wealth-management or cross-border tax specialist pays for itself many times over. On Expert Zoom you can connect with professionals who handle Canada–US relocations for a living.
The practical checklist
Anyone contemplating a Canada-to-US move in 2026 should, well before the departure date:
- Establish the exact date residential ties will be severed, because it fixes the departure-tax calculation.
- Take an inventory of assets subject to the deemed disposition, and separate them from excluded property such as RRSPs and Canadian real estate.
- Decide whether to defer or pay the departure tax on unrealized gains, and understand the security the CRA may require for a deferral.
- Review every Canadian account — TFSA, brokerage, private-company shares — for how it will be treated once you are a US resident.
- Confirm how the Canada–US treaty and foreign tax credits will apply to your new employment income.
Son Heung-min's LAFC chapter will be measured in goals and assists. But behind every high-profile athlete relocation is a team of advisors making sure the move does not cost more in tax than it earns in salary. The lesson for the rest of us is smaller only in scale: crossing the border is a financial event long before it is a lifestyle one, and the planning has to happen before you go.
This article is general information, not tax or financial advice. Cross-border tax outcomes depend on individual circumstances; consult a qualified professional before acting.
