Many investors may not realize that distributions from some holdings in their Tax-Free Savings Accounts (TFSAs) are subject to withholding taxes, costing them potentially thousands of dollars in unnecessary taxes over their lifetimes.
Fortunately, you can avoid some of these hidden withholding taxes by planning which positions to hold in your TFSA, versus which to hold in your Registered Retirement Savings Plan (RRSP) and/or non-registered investment accounts.
In this article, we’ll focus on equities exchange traded funds (ETFs), and explain which types of ETFs to hold in which account to minimize withholding taxes. And we’ll go over the details of how withholding taxes work so you can understand where these taxes come from.
This article is for general information purposes only and does not constitute financial or investment advice.
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What are withholding taxes, and how can TFSA holdings be subject to hidden taxes?
Talking about taxes on earnings in TFSA holdings may seem strange, since investment earnings within a TFSA are exempt from Canadian income taxes.
Withholding taxes are distinct from income taxes, however.
Withholding taxes are taxes that governments levy on income being paid from domestic holdings to foreign investors. The foreign investor could be an individual, a corporation, or an investment fund.
Specifically, if as a Canadian resident you hold a US-listed ETF, any dividends paid to you are normally subject to a 15% withholding tax. For example, if the US-based ETF were to issue its holders a dividend of 1 USD per share, you would receive only 85 cents per share in your investment account. The remaining 15 cents per share is withheld, and sent to the US government.
Under the tax treaty between Canada and the United States, residents of Canada are exempt from this withholding tax for US-listed equities and equities ETFs in their RRSPs, LIRAs (Locked-in Retirement Accounts), and RRIFs (Registered Retirement Income Funds), but unfortunately, not for their TFSAs.
When a Canadian investor holds a US equities ETF in their TFSA, these 15% withholding taxes are applied to every distribution—and there is currently no way to claim the withholdings as a tax credit on your Canadian income taxes, as you can in the case of withholding taxes on US-listed holdings held in your non-registered accounts.
Over the course of a Canadian investor’s lifetime, they could easily end up paying thousands of dollars of withholding taxes on their TFSA holdings, without ever being aware of it.
Fortunately, with proper planning and a consideration of where the ETF is listed and what equities it holds, you can make decisions to minimize your withholding taxes.
Example of withholding taxes
Ashley holds 800 units of a US-listed US equities ETF in their TFSA.
Over a 30 year period, the average annual distribution is 5 USD per unit.
Ashley will lose 18,000 USD to withholding taxes over the 30-year period (800 units x 5 USD x 30 years x 15%).
Where ETFs are listed vs ETF holdings
Withholding taxes work differently depending on where an equities ETF is listed, what holdings that ETF has, and whether the ETF holds those directly or indirectly.
Where an ETF is listed means the country whose exchange the ETF is on, and will also usually determine the currency in which that fund is traded.
For example, a Canadian-listed ETF will generally be listed on the Toronto Stock Exchange (TSX) and will trade in Canadian dollars, while US-listed ETFs are often listed on the New York Stock Exchange (NYSE) and trade in US dollars.
The equities holdings of an ETF refer to the investments the ETF holds, which could be in a different country or countries than the ETF is listed in. For example, a Canadian-listed ETF on the TSX might hold US equities, or a US-listed ETF on the NYSE might hold Brazilian equities.
Direct vs indirect holdings
Directly vs indirectly: in some cases, it can matter whether an ETF holds its holdings directly, such as by having individual stocks of those companies, or indirectly, such as by holding units of another ETF.
To check whether a fund holds its positions directly or through another ETF, check the list of holdings on the fund issuer’s website.
Types of Canadian investments accounts
The table below provides a high-level summary of the most common Canadian investment accounts. In this table, “tax treatment” refers to income tax treatment, not to withholding taxes.
Account type |
Contribution room |
Tax treatment of contributions |
Tax treatment of withdrawals |
Tax treatment of earnings within the account |
TFSA |
Accumulated annually – fixed amount ($7000 for 2025) |
Contributions are not tax-deductible |
Withdrawals are tax-free. |
Tax-free |
RRSP |
Accumulated annually – 18% of the previous year’s earned income. |
Contributions are tax-deductible. |
Withdrawals are added to taxable income. |
Tax-free |
Non-registered |
N/A |
N/A |
Withdrawals are not taxed. |
Taxable |
RRIF |
N/A |
N/A |
Withdrawals are added to taxable income. |
Tax-free |
LIRA |
N/A |
N/A |
Withdrawals are added to taxable income. |
Tax-free |
RRIFs and LIRAs are treated the same as RRSPs for withholding tax purposes. So everything we write about “RRSP” in this article is equally applicable to a RRIF or LIRA.
For those saving for a child’s education in a Registered Education Savings Plan (RESP), the treatment of withholding taxes for an RESP is the same as for a TFSA.
US equities ETFs
To minimize your withholding taxes when investing in US Equities through an ETF, you should generally choose to purchase a US-listed ETF, and to hold that ETF in your RRSP, or, failing that, a non-registered account.
You should generally avoid holding a US-listed ETF in your TFSA.
The below table sets out the withholding taxes implications based on where you hold a US-listed US equities ETF:
Type of account |
Withholding tax implications |
RRSP |
Exempt from withholding taxes. |
TFSA |
15% withholding taxes apply, and are irrecoverable. |
Non-registered |
15% withholding taxes apply, but some may be recoverable using tax credits. |
Due to the tax treaty between Canada and the United States, when you file your Canadian income taxes it’s possible to claim a tax credit for US withholding taxes paid on positions held in your non-registered accounts.
When it comes to minimizing withholding taxes as a Canadian investor, it is always better to gain ETF exposure to US equities through a US-listed ETF held in your RRSP, RRIF, or LIRA.
International equities ETFs
In Canada, non-Canadian, non-US equities are generally referred to as “international equities.”
Unlike US Equities ETFs, international equities ETFs will almost always be subject to some level of withholding tax from the foreign country—this is unavoidable, but may be recoverable through tax credits in some cases for non-registered accounts, depending on the foreign country and which tax treaties are in place.
But if you hold international equities through a US-listed ETF, you may be subject to additional US withholding taxes.
For TFSAs and for non-registered accounts, you should generally gain international equity exposure through a Canadian-listed ETF which holds the international securities directly.
Be on the lookout for Canadian-listed ETFs that gain their international exposure by holding US-listed ETFs (indirect)—these ETFs will incur additional unnecessary withholding taxes. Check the fund issuer’s webpage to look at the fund’s holdings—if the holdings are US-listed ETFs, additional withholding taxes will apply.
For your RRSP (but not your TFSA), you will not incur any additional withholding taxes when you gain international equities exposure through a US-listed ETF (direct).
In the table below, we refer to foreign withholding taxes from a non-US country as “international withholding taxes.”
ETF type |
RRSP |
TFSA |
Non-registered |
Canadian-listed international equities (direct) |
International withholding taxes will apply. |
International withholding taxes will apply. |
International withholding taxes will apply, but may be creditable |
US-listed international equities (direct) |
International withholding taxes will apply. |
Both international and US withholding taxes will apply. |
Both international and US withholding taxes will apply, but the US withholding taxes may be creditable. |
Canadian-listed international equities through a US-listed ETF (indirect) |
Both international and US withholding taxes will apply. |
Both international and US withholding taxes will apply |
Both international and US withholding taxes will apply, but the US withholding taxes may be creditable. |
As we can see in the table above, for international equities ETFs held in your RRSP, there is no difference in withholding taxes between Canadian-listed and US-listed ETFs, so long as the ETFs hold the foreign equities directly.
For your TFSA, in contrast, you’ll be better off gaining exposure to international equities through a Canadian-listed ETF (direct).
For both RRSPs and TFSAs, it is disadvantageous to hold international equities indirectly through a US-listed ETF.
Canadian equities ETFs
When purchasing an ETF to gain exposure to Canadian equities, you should generally choose a Canadian-listed ETF which holds Canadian equities (directly, or through Canadian-listed ETFs).
For Canadian listed ETFs holding Canadian equities, you need not worry about any withholdings taxes, regardless of the account you hold these in: RRSP, TFSA, or non-registered.
In general, you’ll wish to avoid gaining Canadian equities exposure through a US-listed ETF, because you will get dinged with Canada’s foreign withholding taxes (15% of the dividends payable to the US-listed fund).
What about income taxes?
Keep in mind that the above information focuses on withholding taxes only—not on income taxes.
You and your advisor should also take into account income taxes when determining which investments to hold in which accounts.
It makes little sense to choose to hold a foreign ETF in a non-registered account so as to have the withholding taxes recoverable, if you have space in your TFSA and would end up paying more in income taxes than you’d get hit by the withholdings.
Income taxes are extremely complex and depend heavily on your personal situation.
That said, all other things being equal, it’s best to be subject to the lowest amount of withholding taxes possible, and if withholding taxes are unavoidable (due to the composition of your portfolio), to have those taxes be recoverable.
Can I open a TFSA or RRSP as a newcomer?
Usually, yes—you can open a TFSA or RRSP account as a newcomer to Canada.
You need only be considered a resident of Canada for tax purposes in order to open these investment accounts.
Keep in mind that if you cease to become a resident of Canada for tax purposes, that may impact the tax treatment of these accounts.
Remember that it’s important to keep track of your TFSA and RRSP contribution room, as you may face steep financial penalties for overcontributing. You are always responsible for keeping track of your own contribution room—not your financial institution or the CRA.
Who is a resident of Canada for tax purposes?
Most people living in Canada will be considered residents of Canada for tax purposes, regardless of their immigration status (visitor, temporary resident, permanent resident, out-of-status).
Your residency for tax purposes is based on your social and economic ties to Canada, such as maintaining a Canadian address.
If in doubt about whether you are a resident of Canada for tax purposes, you may contact the Canada Revenue Agency for assistance in determining your tax residency.
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