Canadian citizen moving (temporarily) to the US

[anotherjohndoe]

Hello -

I am a Canadian citizen currently living and working in Canada, but have accepted a job in the US (California) and will be moving in May 2014. Hoping to get your insight on a couple questions I have in terms of what I need to plan now, and what to expect when I file taxes next year.

[b]Context[/b]
-Canadian citizen living / working in Canada
-Moving to California in May 2014 on 3-year TN-1 visa
-Job is a permanent position with US employer, but I view this as a 2-3 year commitment before returning back to Canada

[b]Residency[/b]
Do I have an option to maintain Canadian residency, or am I forgone into assuming US residency?

I have read the tax treaty and the language around factual residence is a bit ambiguous - I own no property in Canada, but maintain all family ties here (parents, siblings, etc), will retain Ontario driver's license, and have significant investments that will remain at a Canadian bank (general + TFSA + RRSP). I also have the option to be paid by my US employer into my Canadian bank account, if I so choose.

[b]Implications[/b]
What are the key implications of maintaining Canadian residency vs. transitioning to US?

My understanding based on what I've read so far:
-Income tax rate - limited differential given similar tax structures in California and Ontario (at my income level anyways), Canadian would use foreign tax treaty vs. US would be filing a regular return
-Investment income - no material difference (similar to above)
-TFSA - Canadian would maintain account validity and annual contribution room vs. US would require treating as investment income (...I have already made my 2014 contribution, but my interpretation of the TFSA rules is this is okay since I was a Canadian resident at the time)
-RRSP - Do contribution room calculations include worldwide employment income or just Canadian T4 earnings?
-401-K - Does this require US residency to establish? (my employer offers a matching program)
-2014 Tax Return - it sounds like regardless of approach, I will need to file appropriate documents with both CRA and IRS at the end of this year?
-Anything else?

Thanks in advance.

[nelsona]

You really do not have the option of remaining a CDn tax resident. The treaty will nmakwe you resident the day you move.

Parents and siblings are not ties. Wife and children are, but even that is not enough if you aren't visiting them regularly.

So, act and file like you are leaving in May. Otherwise CRA will push you out anyways.

You will close your TFSA before leaving (you can always re-fund it later). Move your investment accoutns to a US broker. Raise the value of your RRSP by swapping those that have gained since purchased.