Foreign withholding tax
When a foreign corporation pays a dividend to a Canadian, the foreign country usually takes some tax before the money is paid out. The United States withholds 30% from foreign investors by default. The Canada-US tax treaty reduces that to 15% on portfolio dividends. Rates for other countries vary; withholding is commonly between 15% and 25%.
The rules
- No gross-up and no dividend tax credit. A foreign dividend is fully taxable as ordinary income, like interest. Compare Canadian dividends.
- Non-registered account. The tax withheld is claimed back as a foreign tax credit (Form T2209 federally, T2036 for Ontario), which reduces Canadian tax on that income. The credit is the lesser of the foreign tax paid and the share of Canadian tax that belongs to the foreign income. On income from property, such as dividends, the creditable amount is capped at 15% of the income; withholding above that is deducted from income instead.
- No carryover. A credit that cannot be used in the year is lost.
- RRSP and RRIF. Under the treaty, US dividends paid into these are exempt from withholding. See RRSP room.
- TFSA. The treaty does not exempt a TFSA, so the 15% is withheld and there is no Canadian tax against which to claim a credit.
What the engine does
- Takes the foreign tax paid as a figure on a fund or trust distribution in a non-registered account, adds the gross foreign income to taxable income, then applies the federal and Ontario credits within the limits above.
- Claims the credit first, and deducts only the part above the 15% cap.
- Treats the 15% treaty rate as reference only. The amount withheld is an input, because rates differ by country and by account.
What it deliberately does not
- It does not look up a country's rate or work out which holdings are foreign.
- It does not deduct the tax instead of crediting it, which only helps when Canadian tax is near nil.
- It does not model more than one foreign country in a year, foreign business income, or currency conversion.
- The planner's own accounts do not split their return into dividends, so no foreign withholding appears in a plan unless it is entered.