Foreign Withholding Tax Explained

September 17, 2012

The Couch Potato strategy calls for a significant allocation to US and international stocks. When you live in a country with a small, poorly diversified stock market, global diversification is extremely important. But it does carry a price in the form of foreign withholding taxes.

Many countries levy a tax on dividends paid to foreign investors: the rate varies, but for US stocks it is 15%. (Foreign withholding taxes do not apply to capital gains.) With broad-based US index funds now yielding about 2%, the withholding tax amounts to an additional cost of 30 basis points. As you can see, the impact of withholding taxes can be far greater than that of management fees, which get a lot more attention.

To learn how much tax is withheld by your fund, click the “Distributions” tab on its web page and look under the heading “Foreign Tax Paid.” Here’s what the table looks like for the iShares S&P 500 (XSP). Notice the amount of tax paid for 2011 ($0.04388 per share) is approximately 15% of the foreign income received ($0.26866):

XSPInvestors and advisors are often unaware of how foreign withholding taxes affect returns, and the reason is simple: they’re damned complicated. The amount of tax you pay varies with the type of account (taxable, RRSP, TFSA) and the structure of the fund.

What type of account?

Let’s start with account types. If you hold foreign stocks in a non-registered (taxable) account, withholding taxes always apply: if a company pays a 20-cent dividend each quarter, only 17 cents ends up in your account. The good news is you can recover some or all of it by claiming a foreign tax credit on your return. (This can be complex, and I’m unable to provide detailed instructions for recovering withholding taxes. If the amounts are significant, you should consult a professional for help.)

The other key point is that Canada has tax treaties with the US and many other countries that have agreed to waive withholding taxes on stocks held in registered retirement accounts, including RRSPs, RRIFs and Locked-In Retirement Accounts (LIRAs).

Note this exemption does not apply to Tax-Free Savings Accounts (TFSAs). As you will see when you look at the details below, your TFSA may actually be the worst place to hold foreign securities.

What type of fund?

The structure of the fund you’re using for your foreign investments is also extremely important—and even more confusing.

First consider Canadian funds that hold foreign securities directly, which includes mutual funds such as the TD e-Series and some (but surprisingly few) US and international equity ETFs on the Toronto Stock Exchange. Because these funds hold the individual stocks directly, the managers can track the withholding taxes and report them (through a T3 slip) to investors who hold the funds in a taxable account. That allows the investor apply for the foreign tax credit.

However, if you hold these funds in an RRSP, you forfeit the exemption you would otherwise receive on foreign withholding taxes. That’s because the fund itself pays the withholding taxes: you don’t pay it directly. And because you’re investing in an RRSP, the fund won’t issue a T3 slip that would allow you to recover it.

With US-listed ETFs the US withholding tax is recoverable in a non-registered account: you’ll receive a T5 slip that specifies the amount paid. Better yet, if you hold these ETFs in an RRSP, you’re exempt from US withholding taxes. The downside is that when a US-listed ETF holds international stocks there’s an extra layer of withholding tax applied by the stocks’ native countries. There is no way to recover that tax.

The final category is Canadian-listed ETFs that hold US-listed ETFs. These include a number of Canadian iShares and Vanguard funds. Rather than holding their underlying stocks directly, for example, the iShares S&P 500 (XSP) and Vanguard MSCI Emerging Markets (VEE) simply hold units of their New York–listed counterparts (IVV and VWO, respectively).

When you hold these in a taxable account, you can recover taxes withheld by the US-listed ETF, but those withheld by non-US countries are not recoverable. In an RRSP, you get two levels of withholding tax and neither is recoverable, which makes this structure particularly tax-inefficient for international equities.

Confused yet? You’re not alone. To provide you with a handy reference I’ve broken down all of the categories, provided examples of common funds in that category, and summarized the tax implications in each type of account.

A. Canadian fund that holds US or international stocks directly.

TD US Index Fund e-Series (TDB902 and TDB904)
iShares US Fundamental (CLU and
CLU.C)
BMO S&P 500 (ZUE and ZSP)
TD International Index e-Series (TDB911 and
TDB905)
iShares International Fundamental (CIE)

BMO International Equity (ZDM)

  • In a taxable account, US or international withholding taxes apply, but are recoverable.
  • In an RRSP or TFSA, US or international withholding taxes apply and are not recoverable.

B. US-listed ETF that holds US stocks.

Vanguard Total Stock Market (VTI)
iShares S&P 500 (IVV)

  • In a taxable account, US withholding taxes apply, but are recoverable.
  • In an RRSP, US withholding taxes do not apply.
  • In a TFSA, US withholding taxes apply and are not recoverable.

C. US-listed ETF that holds international stocks.

iShares MSCI EAFE (EFA)
Vanguard FTSE Developed Markets (VEA)

iShares MSCI Emerging Markets (EEM)

Vanguard FTSE Emerging Markets (VWO)

Vanguard Total International Stock (VXUS)

  • In a taxable account, international withholding taxes apply and are not recoverable. US withholding taxes apply, but are recoverable.
  • In an RRSP, international withholding taxes apply and are not recoverable. US withholding taxes do not apply.
  • In a TFSA, international and US withholding taxes apply and are not recoverable.

D. Canadian ETF that holds a US-listed ETF of US stocks.

Vanguard US Total Market (VUS and VUN)
Vanguard S&P 500 (VSP and VFV)
iShares S&P 500 (XSP and XUS)

  • In a taxable account, US withholding taxes apply, but are recoverable.
  • In an RRSP or TFSA, US withholding taxes apply and are not recoverable.

E. Canadian ETF that holds a US-listed ETF of international stocks.

iShares MSCI EAFE IMI (XEF)
iShares MSCI Emerging Markets IMI (XEC)
iShares MSCI EAFE (XIN)
Vanguard FTSE Developed ex North America (VEF and
VDU)
Vanguard FTSE Emerging Markets (VEE)

  • In a taxable account, international withholding taxes apply and are not recoverable. US withholding taxes apply, but are recoverable.
  • In an RRSP or TFSA, US and international withholding taxes apply are not recoverable.

For tables suggesting the most tax-efficient account for each type of fund, see this post.

Many thanks to Justin Bender at PWL Capital for verifying the accuracy of this post. For more information, I also recommend this document from Dimensional Fund Advisors, which discusses international (non-US) withholding taxes in detail. This post is intended for educational purposes only and does not constitute tax advice for any individual. You should always consult with a specialist before making any investment for tax reasons.

{ 134 comments… read them below or add one }

Canadian Couch Potato November 3, 2013 at 1:02 pm

@Ryan: The “inefficiency” from holding foreign stocks in a TFSA is pretty small: it is confined to the foreign withholding taxes on dividends. Any capital gains you incur within the TFSA are sheltered from tax, regardless of whether they are from Canadian or foreign securities.

It definitely does not make sense to hold foreign stocks in a non-registered account just to avoid this: in a non-registered account, the entire dividend is fully taxable at your marginal rate. This will have much bigger effect than the foreign withholding tax.

Mk November 18, 2013 at 8:21 pm

For scenario C, if you hold VEA/VWO/VXUS, I would think there would be no US component because they are tracking international equities. Is there even any US withholding tax to consider?

Canadian Couch Potato November 18, 2013 at 8:32 pm

@Mk: Although these ETFs hold international stocks, they are themselves US securities and therefore the US withholding tax will be levied unless the ETF is held in an RRSP.

EH December 7, 2013 at 2:44 pm

Thanks for the informative article. I have a question that relates to US listed ETFs versus Canadian listed ETFs that hold US ETFs. One particular example is Vanguard Canada’s Emerging Markets Index ETF (VEE). It is listed on the TSX and has a MER of 0.33%. It’s sole holding is Vanguard’s Emerging Markets Index ETF (VWO), which is listed on the NYSE. VWO has an expense ratio of 0.18%. Is there any reason for a Canadian investor holding the security in an RRSP to buy the more expensive Canadian ETF, other than any cost in trading CAD to USD?

Canadian Couch Potato December 7, 2013 at 3:10 pm

@EH: The only reason to favour VEE over VWO is the reduced cost of trading in CAD. But don’t underestimate that: if you are paying the brokerage’s usual currency spread, the additional cost could be much higher than the difference in MER and the extra withholding taxes combined.

In a non-registered account (where the withholding taxes are the same), it wouldn’t be unreasonable to pay the extra 0.17% in MER to avoid having to transact in US dollars.

torontonian December 18, 2013 at 12:40 pm

Very useful article. Thanks.
One question: I’m Canadian but I got issued a ITIN and have to present taxes in USA. (as a non-resident). Does this modify the withholding or recoverability of taxes for me?

I asked RBC DI and was told I didn’t have to put my ITIN in the W-8BEN I file with them. But I’m not sure if doing so would bring me benefits or headaches.

satuk December 18, 2013 at 6:28 pm

Hi

For my TFSA account, I am planning to invest in TD e-series index funds – Canadian bond market index, Canadian stock market index , US Stock index and International stock index. Should I be concerned about withholding tax and avoid investing in US and international index funds? I plan to follow the same investment strategy for my RRSP account at as well. Would appreciate guidance on whether I am on right track. Thanks

Canadian Couch Potato December 18, 2013 at 6:38 pm

@satuk: You will pay the withholding taxes in both the RRSP and the TFSA. But this is not a reason to avoid these asset classes: the added diversification is worth the higher costs.

satuk December 18, 2013 at 8:03 pm

Thank you for the quick response. I have a question regarding TD e-series. Can I buy and sell (if needed from TFSA) through my current TD account online (easy web access) or would I need to open a discount brokerage account?

satuk December 18, 2013 at 8:06 pm

Another follow up question – I understand it is individual choice when it comes to investment strategy. But is it ok if I follow the same investment strategy for both RRSP and TFSA or would you recommend otherwise? Thanks

Justin December 18, 2013 at 11:22 pm

@Satuk – You can purchase e-series funds through Easyweb but you need to convert your account to an e-series account. There’s a form to fill out and mail in/bring to a branch.

satuk December 19, 2013 at 9:20 am

@ Justin: Thanks for the response. TD said I need to mail the forms and cannot submit at the branch so I mailed them yesterday.

satuk December 20, 2013 at 5:56 pm

Regarding TFSA, the below was mentioned on cra website:

“You can contribute foreign funds to a TFSA. However, your issuer will convert the funds to Canadian dollars, using the date of the transaction, when reporting this information to the CRA. The total amount of your contribution, in Canadian dollars, cannot exceed your TFSA contribution room.”

Do I need to be concerned about this or would I be buying it in Canadian dollars when I make monthly contributions to US and international funds? Thanks

Lil Du December 29, 2013 at 1:46 pm

This page is really helpful. I have it bookmarked whenever I go visit my parents in Canada and help them with their portfolio.
It would be great if could add information about US bonds as well. I read on http://www.theglobeandmail.com/globe-investor/investor-education/your-tax-rrsp-questions-answered/article4083027/ that there is no withholding tax at all, does that sound right? If so, it would be perfect for TFSAs.

Canadian Couch Potato December 29, 2013 at 2:24 pm

@Lil Du: As you point out, there are no longer withholding taxes on bond interest paid to Canadians. (To double-check, I looked at the Canadian iShares and BMO ETFs that hold US corporate bonds, and the foreign tax paid since 2011 is either zero or negligible.) Therefore, US bonds can be treated like Canadian bonds: they should be held in an RRSP or TFSA and avoided in a taxable account.

Chris January 2, 2014 at 4:12 pm

Thanks for the informative article. Regarding your comment on US bond interest paid to Canadians in a TFSA, would no withholding tax apply to US bond ETFs as well, for instance Vanguard total bond market ETF (BND)? The Vanguard website lists the distribution type as dividends, hence the confusion.

Max January 7, 2014 at 3:21 pm

I understand that a canadian fund of US equities is less tax-efficient in a RRSP, but is it always the most expensive option? Is the typical ammount I will pay in currency exchange fees to buy/rebalance a US fund lower than those taxes? Is there some kind of tool that would make the calculation easy?

Thanks a lot!

Canadian Couch Potato January 7, 2014 at 3:45 pm

@Max: No, US-listed ETFs are definitely not always the cheapest option. It really comes down to how much you pay for currency conversion, which varies a lot. You can tinker with the spreadsheet in this post, though the specific examples here are now out of date:
http://canadiancouchpotato.com/2010/10/18/are-us-listed-etfs-really-cheaper/

Parin January 31, 2014 at 10:58 pm

Thank you for a very comprehensive article on foreign withholding taxes. It appears that if I wish to invest in S&P 500 etf in my RRSP, the only way to avoid the US withholding tax is to hold VTI or IVV.

My concern is US estate taxes as these ETFs are US listed. Does the fact that they are held in a tax sheltered account make any difference?

Canadian Couch Potato February 1, 2014 at 8:46 am

@Parin: Yes, if you want to avoid US withholding taxes in an RRSP, a US-listed ETF is the only option. You are also correct that these are potentially vulnerable to US estate taxes, even in an RRSP or other registered account:
http://business.financialpost.com/2013/02/09/beware-taxes-on-your-u-s-estate/

norman February 25, 2014 at 12:40 am

I want to buy some USA listed Equity Stocks in a taxable account. I have read Canadian Couch Potato articles that say I should try to avoid the expensive currency conversion. My question is if I buy these in an ETF to Cover the US Market is it better to buy a Canadian ETF that holds a US Listed ETF of US Stocks, such as VUN or XUS? Or is it better to purchase a US Listed ETF that holds US Stocks. I will be using my taxable account to buy USA and International Assets and want to try to avoid the currency exchange costs and try to make the tax considerations as simple as possible when buying these types of investments. Can someone please comment on this as I do not fully understand how to make it as simple as possible to mitigate my currency costs and withholding taxes when buying in a Taxable account.
Norm

Canadian Couch Potato February 25, 2014 at 7:44 am

@Norman: If you want to avoid currency conversion then you would have to forget about US-listed ETFs altogether. You could use an ETF such as VUN, XUS or ZSP. If are using a taxable account, there is no difference in taxes between a Canadian-listed ETF that holds a US-listed ETF (like VUN and XUS) and one that holds the stocks directly (like ZSP).

norman February 25, 2014 at 10:50 am

Thanks for the response. I understand it now for USA equities. For International Stocks, excluding USA it seems that I will not be able to avoid withholding taxes in a Taxable account? As I was planning to hold 15% of my stock in a International market and it seems to me that I will have to pay the withholding tax this would be fairly expensive? Is there a way to lessen the cost for taxes and currency exchange costs held like this? Or is it better to hold International Stocks in an RSP or TFSA. I have no room in either that is why I was going to hold my USA and International stock in the Taxable account.

regards
Norm

Canadian Couch Potato February 25, 2014 at 10:55 am

@norman: You can recover the international withholding taxes in a non-registered account if the stocks are held directly by the fund. Not sure if you have seen this more recent post and the accompanying white paper:
http://canadiancouchpotato.com/2014/02/20/the-true-cost-of-foreign-withholding-taxes/

norman February 26, 2014 at 10:14 pm

Thanks CCP I assume the BMO International MSCI EAFE would fall within that classification? According to the Money Sense Magazine All Star Picks 2013 it does hold the stocks directly? I am not sure what the difference is between this fund and Vanguard MSCI EAFE (VEF) fund. The same source says it uses a US Listed ETF as it’s holding. Does VEF have the same ability to recover withholding taxes? Can you explain the difference.
Much appreciated. Norm

Canadian Couch Potato February 26, 2014 at 10:29 pm

@norman: Yes, ZDM holds the stocks directly, while VEF does not. The answers are all in the white paper linked above: ZDM is a Type F fund, while VEF is Type E.

David March 1, 2014 at 1:03 am

Thanks that was very informative.

One thing I want to clarify. It was mentioned above that only US listed etfs holding US stocks are exempt from withholding taxes and that Canadian listed efts holding US stocks are NOT exempt from withholding taxes. I’m not sure if this is true. I just reviewed the tax treaty between Canada and the US in the link below.

http://www.fin.gc.ca/treaties-conventions/USA_-eng.asp

In article XXI (Exempt Organizations), paragraph 2, it states “Subject to the provisions of paragraph 3, income referred to in Articles X (Dividends) and XI (Interest) derived by:

(a) a trust, company, organization or other arrangement that is a resident of a Contracting State, generally exempt from income taxation in a taxable year in that State and operated exclusively to administer or provide pension, retirement or employee benefits…..

shall be exempt from income taxation in that taxable year in the other Contracting State.”

Based on my understanding, as long as the dividends/interest earned from US stocks/bonds in an RRSP, the income is exempt. Please correct me if I’m wrong.

Thanks,
David

Canadian Couch Potato March 1, 2014 at 1:01 pm

@David: The information in the post is accurate. In order to qualify for the RRSP exemption, Canadians must hold the US securities directly. If you hold US stocks in a Canadian-domiciled fund, then technically the fund is the owner of the stocks (although you are the beneficial owner). Some owners of the fund would hold their units in an RRSP and others would hold them in a non-registered account: there would be no way for the IRS to know the difference.

David March 1, 2014 at 10:38 pm

That makes sense. Thanks for clarifying! I really like your site! Helps me plan for my investments.

JF March 5, 2014 at 6:31 pm

Hi Mr. Potato!

I know you wrote this article a while ago and I’ve been reading the comments trying to figure out if it would be a good idea to invest in XSP.TO in my TFSA or RRSP. I know there are a lot of factors in deciding to invest in a non-reg or reg account.

I’m currently using questrade as a new investor and want to invest in an ETF that mimics the S&P 500 index but would benefit me the most in terms of minimal tax being withheld. What are you thoughts and suggestions?

By the way, great article :)!

Pierre-Luc Drouin March 11, 2014 at 12:36 am

How does it work for withholding taxes when DRIP is requested for US-listed ETF shares hold in a taxable account? Is the whole pre-DRIP dividend amount taxed by the foreign country or only the fraction that is not used for DRIP? If the whole pre-DRIP amount is taxed, how does it work for withholding tax deductions when filling the Canadian tax report?

Thanks!

Canadian Couch Potato March 11, 2014 at 12:52 am

@Pierre-Luc: The withholding tax would be deducted from the whole dividend, and any DRIP would be made with what is left over. You don’t need to worry about the calculation: the amount withheld will be reported on your T5 slip, and that’s the amount you claim for the foreign tax credit.

Adam April 2, 2014 at 4:17 am

I am a non-resident Canadian living in Singapore. I own the Vanguard VTI ETF and I pay a 30% withholding tax.
2 questions: 1) Is 30% correct? 2) Can I get any of it back?

Thanks!

Canadian Couch Potato April 2, 2014 at 8:19 pm

@Adam: I have no idea what the tax agreement might between Singapore and the US. However, the normal withholding tax on Us dividends for Canadian is indeed 30%, unless you fill out a W-8BEN form, after which it becomes 15%:
http://www.irs.gov/uac/Form-W-8BEN,-Certificate-of-Foreign-Status-of-Beneficial-Owner-for-United-States-Tax-Withholding

Whether you can recover it, I’m afraid I don’t know. definitely a question for an accountant with expertise in expat situations.

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