Access to USA or Canada not possible passed 45yo?

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TeaLeaf

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#279751 5-Nov-2020 21:46

I really want to move to Canada or USA when things calm down.

But noticed the Canada easy access says 0 points for age once you are passed 45yo.

Is there any other way to access these countries, in layman simple terms? I find all the systems etc a bit of a maze. So hoping somebody has done it or is clued up how to.

No dependants. I have Bach IT 25 years in IT, Mrs has double PHD in Biology and now a senior ecologist along with a project manager of GIS type systems and data for fauna and flora.

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#2598531 5-Nov-2020 22:06

I haven’t reviewed the Canadian system in detail, but age is one category in a skilled migrant test. A zero score for age does not disqualify you for entry, but does mean that other components will need to score higher

TeaLeaf

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#2598591 5-Nov-2020 22:14

stocksp:

I haven’t reviewed the Canadian system in detail, but age is one category in a skilled migrant test. A zero score for age does not disqualify you for entry, but does mean that other components will need to score higher

thanks :). Yeah thats what I assumed, but thinking its going to be damn hard to make up enough points just from 2 other sections. Ugggh, always too late on moving. Was a dream from a young age to live in Canada for a few years. Perhaps learning french would help a lot haha.

gzt

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#2598594 5-Nov-2020 22:19

Do you get extra points for being bilingual in French?

TeaLeaf

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#2598597 5-Nov-2020 22:22

gzt: Do you get extra points for being bilingual in French?

i will have to check tomorrow but I believe so, especially if you are targetting sucn an area. i know german a bit, but little french so far. lived and do live in europe often, just never spent much time in france.

nztim

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#2598600 5-Nov-2020 22:50

If you do get into the US or Canada be careful of your assets back here in New Zealand

Both the US and Canada tax worldwide income and things like Kiwisaver don't have special tax treatment like it does here. The growth within these funds can be punitively taxed under their tax laws

Also if you have a home here in NZ and a mortgage against it the interest in that mortgage can be subject to NRWT tax also if there is a currency fluctuation any gains against the local US/Canadian dollar can be considered taxable income too - This is not a problem if you don't own a home and a mortgage free

Sell your home after you leave? Both those countries have capital gains tax you will have to estimate the value of your home when you become a resident there and if you sell. pay tax on the gains on the sale

Don't sell your home and keep it? Canada has a “departure tax” that is a tax on the gains of your home when you leave Canada. Lets say your house is worth 700k when you arrive in Canada and 900k when you come back to NZ that 200k of gains is Taxable in Canada

Go out, explore the world, but get professional Tax advice from a professional who knows both tax systems to protect your wealth

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Sidestep

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#2598666 6-Nov-2020 06:49

Canada or the US? Very different places, different rules, different outcomes..
Healthcare, housing and cost of living, taxation, superannuation, employment status, quality of life being just a few points to consider.

If Canada, I assume you’re considering applying through Canada’s Skilled Workers Program, which is based on a points system.
There are other paths to residence but that’s the most common.

I don’t think you get extra points for being bilingual - the Language benchmark tests can be taken in English OR French. But being bilingual is usually required for government jobs - Federal or Provincial, and doesn’t hurt - usually helps - when applying for any Canadian job.

Read through some of the many Canadian immigration or expat forums, you’ll find people with the same questions as you.

Don’t worry too much about taxes, property ownership etc. Canada and New Zealand have a ‘tax treaty’ to avoid double taxation.

There are clear tax rules - which aren’t too onerous, unlike US resident’s worldwide taxation - and it’s not hard to find accountants experienced in the field.

Likewise property ownership. In the past 25 years I’ve resided (and owned property) in Australia, the US, NZ and Canada. I currently have property in NZ and Canada - have done for many years, and recently sold a NZ property (during Covid lockdown!).. Understanding and following the rules, paying taxes when due = no problems.

Kiwisaver and Canadian superannuation schemes have clear rules with provisions for change of residency, and NZ and Canada have a comprehensive, and relatively easy-to-understand Social Security agreement.

I see you have no dependents, but if you're thinking of having kids in the near future be aware it might change your plans.

When we decided to slow down and have kids (..before it was too late Lol) I took on Canadian citizenship (both countries allow dual/multiple citizenship).

After having kids we found our Life Goals completely changed, we ended up selling our businesses, and moved back to (rural) NZ when the kids were small - for a planned 10 years - to give them a chance to grow up in NZ and feel like they were Kiwis. A very changed path.

No regrets, they surfed and swam, connected with relatives, learned Te Reo, they and my wife got NZ citizenship.
In 2018 we received an offer we couldn’t refuse and decided to move back to Canada earlier than planned.

The moves both ways were relatively straightforward. School curriculums are similar, both countries allow the tax free import of personal goods. There's regular shipping and flights between both countries. Here, we now live in a nice city with great tertiary education options. Wife's and my new career paths going well.

Finally climate. Be aware Canada generally has cold snowy winters. Winter sports here are big, cross country skiing, snowboarding, ice skating.. Travel to the US/Mexico is cheap. Before kids we managed to align our businesses with yearly travel to warmer climates. With kids in school that changes to 'short breaks' away.
And our planned visit to NZ in February likely won’t be happening this year - Covid.

I love life in Canada - and NZ will always be my homeland. Happy to spend my time shuttling between the two, and glad that's a viable option.
Making the move to live in a different country's a big, serious step.
Good Luck with your plans!

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nztim

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#2598709 6-Nov-2020 08:17

Sidestep:

There are clear tax rules - which aren’t too onerous, unlike US resident’s worldwide taxation - and it’s not hard to find accountants experienced in the field.

My Wife is a US Citizen and tax followed her here to NZ, she has specific wealth advisors on what she can invest in to avoid been slammed

Sidestep:

Kiwisaver and Canadian superannuation schemes have clear rules with provisions for change of residency, and NZ and Canada have a comprehensive, and relatively easy-to-understand Social Security agreement.

Likewise property ownership. In the past 25 years I’ve resided (and owned property) in Australia, the US, NZ and Canada. I currently have property in NZ and Canada - have done for many years, and recently sold a NZ property (during Covid lockdown!).. Understanding and following the rules, paying taxes when due = no problems.

The PIE tax from the growth in Kiwisaver is not Creditable against Canadian or US tax - Yes there are clear rules around superannuation which state country and residence has sole taxing rights

If you are happy to to pay tax in Canada for selling a New Zealand asset where we have no capital gains tax and therefore no foreign tax credit to offset the Canadian Tax & also if you decide to permanently move back to New Zealand pay a departure tax on the gains of all your worldwide assets - Big donation to the Canadian Government I say

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#2598725 6-Nov-2020 08:50

In terms of income tax, based on conversations with one of my brothers who lives in the USA, you’ll probably pay less and be able to offset more than you can here in NZ. The two tier Federal/State tax system might affect that one way or the other depending on what state you end up living in.
Certainly the threshold for higher rate income tax is much more sensible than here in NZ.

nztim

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#2598736 6-Nov-2020 09:08

Geektastic: In terms of income tax, based on conversations with one of my brothers who lives in the USA, you’ll probably pay less and be able to offset more than you can here in NZ. The two tier Federal/State tax system might affect that one way or the other depending on what state you end up living in.
Certainly the threshold for higher rate income tax is much more sensible than here in NZ.

General income tax is not a problem, when you leave NZ and rent out your house you complete an IR3NR in NZ and a Tax return in either Us or Canada and the tax you pay in NZ is creditable against Canadian and US tax (that part is easy)

Kiwisaver (and other mutual fund investments) are not considered Income for NZ Tax Purposes, They grow and the Fund pays tax on your behalf at your described PIR Rate - this is a Huge problem when moving abroad because while it is not considered income in New Zealand it is often considered income in your country of residence and because the fund is been taxed not you, there is no foreign tax credit to offset this - This problem is exemplified if you move to the USA (or if you are a US Citizen living in New Zealand) this is because foreign mutual funds are considered Passive Foreign Investment Companies or "PFICS" this requires punitive reporting (Form 8621) and heavy taxation (up to the maximum Tax Rate in the US of 37% even if you don't fall into that tax bracket)

Mortgage interest on your New Zealand Mortgage is subject to non resident withholding tax in the country of residence (usually 10%) - If you own your house outright this is obviously not an issue

And as mentioned above capital gains tax (including currency fluxuation)

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BlinkyBill

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#2598744 6-Nov-2020 09:37

NZTIM, if you re-locate, would you not become a non-resident of NZ and would your tax rate in NZ change to non-resident, and therefore tax treatment of KiwiSaver earnings not change accordingly? Your argument appears to be presented on the basis of a resident tax code basis.

Also, NZ residents are taxed on world-wide income, with tax agreements with many country’s balancing against double-taxation.

If you are a resident of say USA, and capital gains on house sales are taxed, then that is the basis of your taxation ... so what?

really, the basis for taxation is not a reason to not move abroad, it is what it is.

Sidestep

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#2598755 6-Nov-2020 10:04

BlinkyBill:

really, the basis for taxation is not a reason to not move abroad, it is what it is.

This.
There's the old saying about “Stepping Over Dollars to Pick Up Dimes”

And nztim you might be confusing US and Canadian tax law.

For instance the PFIC regime is a particularly US thing to stop US investors ‘hiding’ income overseas. There’s a big difference in the way the US and Canada treat foreign investment/income - it seems you just can’t escape the IRS unless you revoke your US Citizenship.

I'm not a tax planner, accountant or lawyer, but do employ them when necessary - to get advice on structuring things correctly so as to only pay my fair share of tax.
For instance Canada’s $100K tax free limit on “specified foreign property” excludes personal-use real estate - such as land in NZ in certain circumstances.

We did a complete 'deemed disposition' of our assets on departure from Canada in 2010 to reside in NZ, correctly organised our affairs for our move from NZ back to Canada in 2018.
Neither country imposed unreasonable or punitive taxes on us, there are many exemptions designed to make the process fair.

As I said NZ and Canada have a tax treaty. There’s also a Canada - U.S. tax treaty which - usefully - allows me (as a Canadian taxpayer) to avoid U.S. withholding tax on certain U.S. investments. Filling out W8-BEN’s is a small price to pay..

My wife and kids do hold Kiwisaver accounts and they are correctly taxed.

Over the years I've had an Australian self-directed Super scheme, US 401-k, and NZ Kiwisaver account.

Canada has equally good, if not better options for tax-sheltered growth for retirement savings, kid's education or just tax-free general saving. Things like TFSA's, RESP's, RRSP's-RRIF's and their treatment of Universal Life policies can allow those willing to work hard and save to accrue real long-term gains.

Tax Free Savings Accounts, in particular, are a great idea - something I’d like to see in NZ.

As BlinkyBill says - don't let the fear of paying taxes prevent you from making a move that may be life-changing.
And do consult an accountant/tax planner.

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Geektastic

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#2598773 6-Nov-2020 10:33

nztim:

Geektastic: In terms of income tax, based on conversations with one of my brothers who lives in the USA, you’ll probably pay less and be able to offset more than you can here in NZ. The two tier Federal/State tax system might affect that one way or the other depending on what state you end up living in.
Certainly the threshold for higher rate income tax is much more sensible than here in NZ.

General income tax is not a problem, when you leave NZ and rent out your house you complete an IR3NR in NZ and a Tax return in either Us or Canada and the tax you pay in NZ is creditable against Canadian and US tax (that part is easy)

Kiwisaver (and other mutual fund investments) are not considered Income for NZ Tax Purposes, They grow and the Fund pays tax on your behalf at your described PIR Rate - this is a Huge problem when moving abroad because while it is not considered income in New Zealand it is often considered income in your country of residence and because the fund is been taxed not you, there is no foreign tax credit to offset this - This problem is exemplified if you move to the USA (or if you are a US Citizen living in New Zealand) this is because foreign mutual funds are considered Passive Foreign Investment Companies or "PFICS" this requires punitive reporting (Form 8621) and heavy taxation (up to the maximum Tax Rate in the US of 37% even if you don't fall into that tax bracket)

Mortgage interest on your New Zealand Mortgage is subject to non resident withholding tax in the country of residence (usually 10%) - If you own your house outright this is obviously not an issue

And as mentioned above capital gains tax (including currency fluxuation)

Yes and you get a kind of reverse problem moving a UK pension to NZ. UK pension savings are not taxed at all, so you have more money earning for you throughout your working life. The money is taxed (a certain amount may be removed tax free first) as income once you start taking your pension.

However move the capital from the pension fund in the UK to NZ and NZ will stick you with a massive tax bill...for money you already own and which you did not earn in NZ..!

BlinkyBill

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#2598790 6-Nov-2020 11:06

Geektastic:

Yes and you get a kind of reverse problem moving a UK pension to NZ. UK pension savings are not taxed at all, so you have more money earning for you throughout your working life. The money is taxed (a certain amount may be removed tax free first) as income once you start taking your pension.

However move the capital from the pension fund in the UK to NZ and NZ will stick you with a massive tax bill...for money you already own and which you did not earn in NZ..!

So what? We have a different tax regime in NZ and if you want to live here you agree to that regime.

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#2598792 6-Nov-2020 11:08

Geektastic:

Yes and you get a kind of reverse problem moving a UK pension to NZ. UK pension savings are not taxed at all, so you have more money earning for you throughout your working life. The money is taxed (a certain amount may be removed tax free first) as income once you start taking your pension.

However move the capital from the pension fund in the UK to NZ and NZ will stick you with a massive tax bill...for money you already own and which you did not earn in NZ..!

Geektastic,

Could you point me towards the source of your comment above that I have bolded? The IRD have taxed every cent of my UK Occupational Pension so if that's an error by them it could be quite beneficial to me.

nztim

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#2598839 6-Nov-2020 11:19

BlinkyBill:

NZTIM, if you re-locate, would you not become a non-resident of NZ and would your tax rate in NZ change to non-resident, and therefore tax treatment of KiwiSaver earnings not change accordingly? Your argument appears to be presented on the basis of a resident tax code basis.

Also, NZ residents are taxed on world-wide income, with tax agreements with many country’s balancing against double-taxation.

If you are a resident of say USA, and capital gains on house sales are taxed, then that is the basis of your taxation ... so what?

really, the basis for taxation is not a reason to not move abroad, it is what it is.

Correct, if you leave NZ you will become non resident for tax purposes and therefore Income (from renting out your house) would be taxed at Non Resident rates, Kiwisaver would automatically move to 28% as with other PIE tax schemes - But remember it is tax paid by the fund on your behalf not by you (NZ does not consider Kiwisaver Growth Income) This means that 28% tax credit cannot be used to offset income tax in your new country of residence

Like wise moving to NZ TSFA (Canada) and ROTH IRA (US) are not taxed at all there, but are fully taxable income here - and if the balance is over $50,000 NZD FIF Tax rules apply and you could be hit with currency fluctuation tax. Luckily RRSPs and Traditional IRAs are not Taxable income in New Zealand until they are withdrawn at retirement and the CRA (Canada) and the IRS (US) give up their taxing rights on withdrawal in New Zealand and the IRD is the only one that has taxing rights

I also agree with others posts that Tax should not be a reason not to cross boarders however you need to speak with an experienced accountant to get your affairs in order

Any views expressed on these forums are my own and don't necessarily reflect those of my employer.

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