CRA treatment of Roth Conversions

[cfn2007]

I understand that the new US-Canada Treaty protocol allows Roth money to be sheltered from Canadian tax as long as the contribution (or conversion) was done while a resident of the USA (i.e. prior to moving to Canada).

What would happen if a US citizen converted his 401k into a Roth IRA while living in another country (perhaps somewhere in Asia) and then moved to Canada. Would this Roth conversion be sheltered from Canadian taxes? Or is it a necessary condition that the conversion be done as a US resident?

Thanks.

[nelsona]

The condition is that it be done as a non-resident of canadaof course, . the reference to being in the US is because of the liklihood of the situation.