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The US Department of Government Efficiency (DOGE) recently announced that it discovered massive fraud against the Social Security retirement program, citing 130 year-olds collecting Social Security payments as an example.

Against that backdrop, the Social Security Administration (SSA) has changed how people must prove their identity when 1) claiming benefits for the first time and 2) changing bank accounts for direct deposit of benefits checks. 

The new procedure will be burdensome for noncitizens and for applicants who are not tech-savvy, especially now that DOGE has eliminated much of the SSA IT staff at a time when the SSA website is experiencing frustrating outages and crashes.

Nevertheless, the following changes go into effect on April 14, 2025:

• Identity can no longer be verified by phone.
• Identity can be verified when people apply for benefits online at https://www.ssa.gov/apply.
• People who prefer not to apply for benefits online and those who are unable to prove their identity online may make an appointment (+1 800-772-1213) to complete the application process and verify their identity in person at a Social Security field office.

To apply online for benefits or for a direct deposit change, applicants will need the following:

• Current valid photo ID (e.g., driver license or passport)
• Digital images of the photo ID (for a driver license, that is front and back of the card)
• A smart phone with internet access
• Social Security Number (SSN)
• Information regarding prior marriages that lasted more than 10 years or ended in the death of a spouse
• Information about minor children and disabled older sons/daughters
• US military service information
• Current employment information
• Information about any previous employment within the last two years
• Direct deposit information (new bank routing number, account number, etc.)

US citizens (and noncitizens with Social Security numbers) applying online will be asked to create a mySocialSecurity account (or use one they already have). Certain noncitizens may be unable to create such an account. These individuals will need to schedule an appointment by phone (see above) and complete the application process at a Social Security field office.

In the process of creating a mySocialSecurity account online, the applicant must present an ID.me digital credential as evidence of identity. Applicants who lack an ID.me credential will be given an opportunity to create one online while setting up the mySocialSecurity account. To receive an ID.me credential, the applicant must upload a photo ID as well as a video selfie for comparison to the photo ID.

Receiving verification codes by text, creating still images and video selfies, and uploading files to a website may be beyond the technical know-how of many Social Security applicants. Many people will opt-out of online processing because of the technical requirements and/or glitches.

Fortunately, the ID.me program has live support staff available to help. The alternative is to make an appointment and complete the process at a Social Security field office. Please note that due to staff shortages at the SSA, field offices may be overwhelmed, and long wait times for an appointment can be expected.

What are the practical implications of this new process?

• ID.me is a handy credential to have. It is becoming the digital key for accessing your personal accounts across federal government agencies and programs.
• Even though a thorough background check is not performed on ID.me applicants, that doesn’t mean that anyone who asks for an ID.me credential gets one. Expect that certain data and documents may trigger delays in processing. The following kinds of data/documentation typically trigger delays:
  • Data and documents (such as birth, marriage, employment documents, and photo IDs) that are issued by countries hostile to US foreign policy interests
  • Photo IDs from countries that essentially sell citizenships and passports
  • IDs issued in languages other than English
  • Third-country passports issued by a country other than one’s country of birth
  • Data associated with birth, marriage, and employment when the country providing the data is different from the country that issued one’s photo ID
  • Substantial changes in facial appearance since the issuance of the photo ID
  • The applicant was discharged from the US military under circumstances that were other than honorable, medical, or administrative
  • The applicant has currently, or in the past, appeared on a US no-fly list
  • The applicant has a criminal record anywhere in the world
• Current Canadian driver licenses and passports are routinely accepted for ID.me.
• US citizens and dual Canadian-US citizens submitting a third-country photo ID may face delays in processing.
• Creating a new mySocialSecurity account or a new ID.me credential because you forgot the login information is strongly discouraged. Instead, you should seek advice from a customer service representative about how to proceed.
• You should apply for benefits 90 days before you want them to begin, because the process is not entirely automated and there may be unexpected delays.

The good news is that this should be a once-in-a-lifetime task!

Imagine you’re a U.S. citizen or Green Card holder living in Canada, and you’ve just received the dreaded notice: your U.S.-based brokerage or custodian has decided they can no longer hold your taxable investment account or IRA because you live abroad. They’re giving you 60 days to transfer it elsewhere, or they will liquidate everything and provide you with a check.

Cue the panic—right?

No, just take a breath. Although this scenario is increasingly common, there are practical solutions. Here’s a breakdown of your options and considerations, compiled for you by Cardinal Point.

First, Why Is This Happening?

There are several reasons your U.S. financial institution no longer wants to hold your investment accounts:

1. Regulatory Landscape and the Foreign Account Tax Compliance Act (FATCA):Many U.S. financial institutions have been tightening restrictions on clients with foreign addresses due to risk management and compliance burdens such as FATCA. Maintaining accounts for U.S. persons abroad requires additional reporting, and many brokerages have simply chosen to avoid the complexity.
2. Securities Laws and Compliance Requirements: Both the financial institution and the investment advisor must have a securities license and be registered in the jurisdiction in which their client resides. Even if a client’s investment accounts are held in the U.S. at a U.S. financial institution, if that client resides in Canada, the firm holding or acting as a custodian for the account, as well as the individual or financial advisor rendering investment advice, must be registered in the Canadian Province where the client resides.  Unfortunately, most U.S.-based financial professionals are not registered to provide investment advice in Canada.
3. Tax Reporting Conforming to U.S. and Canadian Standards: While U.S. financial institutions generate annual tax documents and slips that conform to U.S. tax reporting standards, they do not provide the equivalent Canadian documentation needed for residents of Canada to file their Canadian taxes.

Solutions if You Have a Taxable (Non-Retirement) Investment Account

If your U.S. brokerage is closing your taxable brokerage account, your options include:

Transfer to Another U.S. Brokerage That Accepts Non-Residents

Some U.S. brokerages may still accept U.S. expats, though the list is shrinking. You’ll likely need:

• Proof of a valid Canadian mailing address in your name,
  • It is important that you report the address where you actually live, not an inaccurate location such as a relative’s address in the U.S. in an attempt to fool the authorities. State tax officials have caught on to that – and are catching people who use incorrect U.S. addresses. Then they send notices requiring that a state tax return be filed and state taxes be paid in full on investment income and realized gains earned in the account with the incorrect address.
• Proof of U.S. citizenship, and
• To speak directly to the U.S. brokerage and confirm that they do, indeed, still accept expat clients before initiating any transfers.

It is also possible to work with a qualified cross-border financial advisory firm, like Cardinal Point, which is dually licensed in both Canada and the U.S. as a registered investment advisor and specializes in holding U.S. taxable and qualified (retirement) accounts for U.S. expats. Cardinal Point has worked with U.S. custodians on this issue for more than12 years and has customized solutions for clients in this exact situation.  In addition to all other facets of financial and tax planning, Cardinal Point will take care of the account paperwork for you to continue holding your U.S. taxable investment accounts in the U.S. with full compliance.

Liquidate and Move the Funds to Canada

You could sell the holdings at the U.S. custodian and transfer the cash to a Canadian financial institution. However, this can potentially incur the following consequences:

• Capital gains tax in the U.S. (and potentially in Canada if you are already a Canadian tax resident),
• Currency exchange costs when converting from U.S. dollars to Canadian dollars, and
• Loss of tax deferral or growth potential.

Once the funds are in Canada, you can invest through a Canadian brokerage, but managing U.S. tax reporting becomes more complex, especially for mutual fund corporations considered PFICs (Passive Foreign Investment Companies), which can have punitive U.S. tax treatment and additional annual U.S. tax reporting.

Some investments, such as individual stocks and ETFs, can move in-kind (without immediate tax implications) from the U.S. custodian to a Canadian custodian. However, this can be very difficult to accomplish on your own, as it is uncommon and requires extensive coordination with both U.S. and Canadian custodians. Once they are moved, it also necessitates adjustments to the U.S. and Canadian dollar cost basis for that move plus all future transactions. Luckily, solving these problems for clients is what a cross-border financial advisory firm such as Cardinal Point specializes in, in addition to all other aspects of cross-border investment, financial, tax, insurance, and estate planning.

Solutions if you Have an IRA (Traditional or Roth)

Many U.S. custodians will not allow IRAs to be held by non-U.S. residents. Your options include:

Find a U.S. Custodian That Allows IRAs for Non-Residents

This is the cleanest option, but not all custodians will help.

Do NOT attempt to directly transfer an IRA to a Canadian RRSP – direct transfers are not allowed, and trigger a full distribution and adverse tax implications. An indirect transfer is allowed, however, and can be beneficial under certain circumstances after modeling out the U.S. and Canadian tax implications with a cross-border tax advisor. 

Take a Distribution (Not Ideal)

If no U.S. custodian will take your IRA, your current custodian may force a distribution, resulting in:

• Possible tax payable in the U.S.: Traditional IRA distributions are taxable; Roth IRAs are tax-free only if qualified,
• Possible 10% early withdrawal penalty if you’re under age 59½, and
• Possible tax payable in Canada: Depending on the type of IRA, whether or not you’re a Canadian tax resident, and whether or not you properly elected tax-free treatment for a Roth IRA with the Canada Revenue Agency, the withdrawal may also be taxable in Canada. The U.S.-Canada Tax Treaty can provide assistance to avoid double taxation, but you will pay the higher Canadian tax rate on the taxable distribution.

Work with a Cross-Border Financial Advisory Firm

Cardinal Point can continue holding your Traditional and Roth IRAs at a U.S. custodian.  Cardinal Point has worked with U.S. custodians on this issue for more than12 years and has created solutions that are customized for clients in this exact situation. Cardinal Point will take care of the account paperwork for you to properly continue holding your U.S. IRA(s) in the U.S. and will provide tax/financial/estate planning on future distributions from these IRAs to ensure you are paying the minimum required amount of tax and passing the maximum amount to your beneficiaries as possible.

What Can You Do Now?

1. Act Quickly – 60 days isn’t much time. Start calling alternative custodians or reach out to a cross-border financial advisory firm, like Cardinal Point, ASAP.
2. Get Professional Help – This is a tax and legal minefield. A cross-border planning firm such as Cardinal Point, can save you time, money, stress, and regret.
3. Don’t Leave Funds in Limbo – If your account is liquidated and you don’t transfer the assets, the custodian may send you a check, potentially triggering costly taxable events or complications with your Canadian bank.
4. Avoid PFIC Traps in Canada – If you move your investments to a Canadian brokerage, be mindful of Canadian mutual fund corporations that may be taxed harshly under U.S. rules.

Final Thoughts

The problem outlined above is frustrating, but certainly not insurmountable. The key is to be proactive and choose custodians and strategies that align with your cross-border status. The worst thing you can do is to ignore the notice from your U.S. brokerage or assume it’s not urgent.

Need help figuring out your next step? Consult a cross-border financial planning firm, like Cardinal Point, for experienced, qualified guidance to successfully navigate the ins and outs of U.S.-Canada investing.

It is the end of an era. Pursuant to a January 20 presidential executive order, the US is changing the rules for foreign nationals, including some Canadian snowbirds, who enter the US as visitors without visas.

Who must register:

Beginning April 11, the following visitors without visas (including infants) who are not otherwise exempt must register:

• Those planning a visit of 30 days or longer
• Those already in the United States on April 11 who plan to stay (or who have stayed) 30 days or longer
• Those who enter for less than 30 days but end up staying 30 days or longer.

To register:

1. Create an individual account on the USCIS.gov website. Do not create a second account if you already have an account unless instructed to do so.
2. From that personal account, complete form G-325R online. G-325R asks for:
   • Full Legal Name
   • Date and Place of Birth
   • Date and Place of Entry into the United States
   • Current US Address and Contact Information
   • Immigration Status (if applicable)
   • Criminal History (if applicable)
3. While there is a fingerprinting requirement, citizens of Canada are exempt from fingerprinting under an interim rule. It seems likely that they will be exempt under the final rule as well.

Foreign nationals 14 years of age and older who are merely Permanent Residents of Canada will probably be subject to fingerprinting. Those who reach the age of 14 during their stay will need to apply for fingerprinting and be fingerprinted within 30 days.

However, the new rules do not apply to those who are exempt:

• Canadian visitors who receive an I-94 Arrival/Departure document when they enter (typically air travelers)
• NEXUS participants
• Visa Waiver Program participants, and
• Indigenous people, in certain circumstances.

Registrant responsibilities:

Registrants will have essentially the same responsibilities that other foreign nationals already have, including nonimmigrants with visas and green card holders (even if they are unaware that they have these responsibilities):

• Inform the Government regarding each change of US address within 10 days per the process that the Government provides,
• After every entry, go online and confirm that the I-94 that you have been issued is in the Government data system and that the date is correct: I-94 Official Website – Home Page Keep in mind that entering the document and data correctly is not the Government’s responsibility. That is your responsibility.
• Carry evidence of registration on your person at all times (USCIS will provide documentation),
• Register again before each entry (It is not 100% clear at this point, but it seems likely that even a registrant who takes a day trip to Mexico will need to register again.)

Willful failure to register is a crime punishable by a fine of no more $5,000 and/or imprisonment up to six months. Fraud related to registration is also a crime.

Interim regulations have been posted to the Federal Register as required for a comment period.

Why punish snowbirds?

Registration is not intended to punish Canadian visitors who don’t have visas. Rather, registration is designed to eliminate a potentially dangerous blind spot for America in managing its borders. Registration allows the US to collect data from the two or three million annual visitors from Canada, which is the same data it already collects from virtually every other foreign national. The responsibilities and protocols associated with registration should be familiar to every foreign national with a visa or green card, and from now on, Canadian visitors without visas will be treated like everyone else.

Given America’s unique (and historically warm) relationship with Canada, the Trump Administration could and should have done a better job of rolling out the registration program.

What are the practical implications of registration?

From now on, assume that US immigration authorities, including every border control officer you encounter, will have excellent records of how much time you spent in the US, and those will be available to every border control officer.

Be diligent about monitoring your length of stay. Get in the habit of counting days spent in the US. Mark a calendar. A multi-year calendar is ideal for tax reasons (discussed below).

Depart before your 183rd day to remain compliant with US immigration authorities. Assume staying in the US for more than 182 days has consequences. Staying merely an extra day or two could mean that your next stay is limited to a few weeks. Any time restriction imposed will be documented on your new I-94,your passport, or both.

Understand what resets the visitation clock (calendar), allowing you another 182 days. Merely leaving the US does not reset the clock. You must spend months abroad for the rest to be granted, and at this time we don’t know how many months are required. But it does appear likely that the glory days of spending seven months in the US soaking up warm sunshine under the radar are over.

Understand the IRS Substantial Presence Test and avoid it. For immigration purposes, the magic number is 182 days. But the US Internal Revenue Service (IRS) has its own magic number. Spending too many days in-country can trigger US tax residency based on IRS calculations.

What’s the IRS magic number? It’s considerably less than 182, and is actually just 31 days in the current year plus 180 days during the previous three years. More specifically, the Substantial Presence Test formula used in that calculation is: 1) all of the days in the current year, plus 2) one-third of the days last year, plus 3) one-sixth of the days in the previous year.

The Substantial Presence Test does NOT mean that you need to spend less than forty-five days in the US annually. There are steps you take and strategies you can follow to lawfully avoid triggering Substantial Presence while you still enjoy your months in the sun. But it is strongly advised that you consult a qualified cross-border tax expert to ensure you do not subject yourself to IRS consequences.

The impetus to explore options:

The beauty of “visitor without a visa” status was zero effort, zero headaches, and almost zero risk. As of April 11, the effort and headaches are rather significant, and ignoring the risks can result in substantial immigration visa and taxation complications.

Understandably, some Canadians will find this registration regime unwarranted and even insulting, and they’ll choose to avoid the US and spend their time and loonies elsewhere.

We can hope that at least a plucky few will see registration, the end of an era, as a strong motivation to explore other US immigration options and strategies. There are multiple options and Cardinal Point can help you understand each of them, so you can select the one that best suits your needs and goals.

Kris Rossignoli, Senior Private Wealth Manager at Cardinal Point Wealth Management, was recently featured in The Globe and Mail article, “Flee Canada? Companies considering a U.S. move quickly learn it’s costly and complicated – and can even backfire.” In the article, Rossignoli offers expert commentary on the financial, tax, and immigration challenges Canadian companies face when considering relocating operations to the U.S.

Drawing from his extensive experience in cross-border wealth and tax planning, Rossignoli highlights key obstacles, such as Canada’s departure tax—typically 25% of net assets—as a major deal-breaker for many businesses. He also underscores the complexity of physically moving operations and obtaining U.S. immigration visas, warning that the steep financial and logistical costs often outweigh the perceived benefits of redomiciling.

His insights support the growing view among cross-border financial professionals that most Canadian companies are better off staying put—unless they have substantial operations in the U.S.

To learn more and read the full article below:

Kris Rossignoli, Senior Private Wealth Manager at Cardinal Point Wealth Management, is a leading voice in cross-border financial planning, guiding clients through rising uncertainty as the U.S. trade war intensifies. Featured in The Globe and Mail article “Five questions cross-border experts are facing as trade war escalates,” Rossignoli offers expert insights into the growing concerns of his clients with ties across the U.S.-Canada border.