Roth 401k (vs. Roth IRA) - taxed in Canada?

[skobes]

I am a dual US/Canadian citizen planning to move from the US to Canada. I have a 401k plan with pre-tax and Roth sub-accounts. In addition, I have a Roth IRA.

I've read that for the Roth IRA, a "one time election" can be filed with the CRA to get tax free distributions, assuming no contributions are made after moving to Canada.

I'm trying to figure out if this applies to the [b]Roth 401k[/b] also.

An accountant at PwC told me the one time election only works for the Roth IRA, and not the Roth 401k. But they also said they had not researched the latest changes to the US-Canada tax treaty, and I found an article online that suggests otherwise:

https://www.sunnet.sunlife.com/files/ad ... o_RRSP.pdf
"Roth IRA and [b]designated Roth account[/b] withdrawals that wouldn't be taxed in the US won't be taxed in Canada"

Can anyone confirm if Canada taxes earnings or distributions of a Roth 401k? Does it require the same one-time election process as a Roth IRA? Is there an authoritative source I can point to which addresses this?

Thanks!
Steve

[nelsona]

The Roth401(k) is treated the same.

And so would the rollover Roth that would typically be created when you move the funds from the company plan to your own plan, as many do.

The treaty covers this in detail, and uses terms like Roth or similar plans.

[skobes]

Excellent, thanks for the quick response!