Retirement and savings accounts compared across the United States, Canada and India shows that each country built a different mix of employer plans, personal tax-deferred accounts and government savings schemes. The U.S. relies on the 401(k) and the IRA. Canada offers the RRSP for deferral, the TFSA for tax-free growth and the FHSA for a first home. India has the Employees' Provident Fund (EPF), the Public Provident Fund (PPF) and the National Pension System (NPS). This page compares the 2025 and 2026 limits and the structure of each, then explains the traps that arise when you move between the three countries and the accounts do not move with you.
Retirement and savings accounts compared: the main vehicles
| Purpose | United States | Canada | India |
|---|---|---|---|
| Employer plan | 401(k), 403(b), SIMPLE IRA | Registered pension plans, group RRSP | EPF and employee pension scheme |
| Personal deferral account | Traditional IRA | RRSP | NPS (Tier I) |
| Tax-free growth account | Roth IRA, Roth 401(k) | TFSA | PPF (resident individuals) |
| Housing or education | Limited early-withdrawal exceptions | FHSA, RESP | Provident fund withdrawals for specified purposes |
| State pension | Social Security | CPP and OAS | Employees' Pension Scheme and other schemes |
| Who can join | Workers with U.S. income | Canadian residents with earned income or room | Varies: EPF for covered employees, NPS for citizens including non-residents, PPF for residents |
Limits for 2025 and 2026
| Item | 2025 | 2026 |
|---|---|---|
| U.S. 401(k) employee deferral | $23,500 | $24,500 |
| U.S. IRA | $7,000 | $7,500 |
| U.S. IRA catch-up (age 50 or older) | $1,000 | $1,100 |
| U.S. SIMPLE IRA | $16,500 | $17,000 |
| Roth IRA phase-out, single | $150,000 to $165,000 | $153,000 to $168,000 |
| Roth IRA phase-out, married filing jointly | $236,000 to $246,000 | $242,000 to $252,000 |
| Canada RRSP dollar limit | $32,490 | $33,810 |
| Canada TFSA annual limit | $7,000 | $7,000 |
| Canada money purchase plan limit | $33,810 | $35,390 |
| Canada year's maximum pensionable earnings (YMPE) | $71,300 | $74,600 |
The IRS publishes the U.S. figures in its annual announcement. The CRA's table gives the Canadian figures. The RRSP deduction limit is 18% of your earned income from the previous year up to the dollar limit, so the 2025 limit applies to 2024 earnings. The CRA gives March 2, 2026 as the deadline to contribute for the 2025 tax year, and excess contributions of more than $2,000 above your limit can trigger a tax of 1% per month. For the FHSA, the first-year participation room is $8,000, with carry-forward rules on the CRA's pages. India does not publish a single annual cap for EPF; contributions follow wages, and the Rs 15,000-a-month wage ceiling for compulsory coverage has applied since September 2014. See the Canada accounts explainer for how the registered accounts work.
The Indian schemes in more detail
- EPF. A covered employee drawing up to Rs 15,000 a month must contribute 12% of wages, and the employer contributes 12%.
- PPF. The government's scheme rules say NRIs are not eligible to open a new account; an account opened as a resident can run to maturity under conditions.
- NPS. PFRDA says Indian citizens, resident or non-resident, and Overseas Citizens of India aged 18 to 85 can join the All Citizen model. Tier I is the tax-advantaged retirement account, and NRIs and OCIs with Tier I cannot activate Tier II.
- NRE, NRO and FCNR accounts. These bank accounts are governed by foreign exchange rules; see NRE, NRO and FCNR accounts.
Indian tax benefits for these schemes differ between the old and new tax regimes, and the Income-tax Act, 2025 started on April 1, 2026, so your CA confirms the benefit for the year.
How are withdrawals taxed at home?
In general, money taken from a traditional U.S. 401(k) or IRA is taxed as ordinary income, while qualified Roth withdrawals are not. In Canada, RRSP withdrawals are added to income and may carry withholding at source, while TFSA withdrawals are not taxed in Canada. In India, the result depends on the scheme, the type of payout and the tax regime in force when you withdraw, so your CA must confirm it. The key cross-border point is that the country where you live when you withdraw may tax the payout, while the country that hosts the account may withhold, which is why treaty rules and the timing of a move matter. Record the balance of every account on your move date, because that figure is often the starting point for later gain and income calculations.
What changes when you cross borders?
| Account | U.S. view (general) | What to do |
|---|---|---|
| Canadian RRSP or RRIF | Treaty relief usually lets a U.S. resident defer U.S. tax on growth | Disclose accounts; keep statements |
| Canadian TFSA | Not recognized as tax-free, so income and gains may be taxable each year and extra forms can apply | Review before moving; see the RRSP, TFSA and RESP guide |
| Indian EPF | Employer contributions and interest may be taxable in the U.S. depending on facts | Get a CA statement; see the foreign retirement guide |
| Indian PPF and NPS | Treatment depends on the scheme; the U.S. has no special relief | Ask before contributing from the U.S. |
| U.S. 401(k) or IRA | Tax-deferred in the U.S. | Canada and India have their own treatment for residents; check before moving |
Foreign accounts also create reporting duties. Some retirement accounts are excluded from the FBAR but may appear on other forms, and Indian mutual funds held inside a plan or outside it may be passive foreign investment companies. See cross-border retirement planning and our foreign account reporting service.
A worked example
Priya moves from Toronto to Naperville in 2026. She holds CAD 150,000 in an RRSP and CAD 60,000 in a TFSA, and her new employer offers a 401(k). In 2026 she can defer up to $24,500 of her own pay into the 401(k) (the IRS employee limit), and any employer match is extra. Her RRSP deduction room is no help without Canadian taxable income, so she stops contributing and keeps the account. The U.S. treaty lets her defer U.S. tax on the RRSP's growth, but she must disclose the account. The TFSA is where care is needed because the U.S. does not treat it as tax-free; she may withdraw or keep it depending on the forms and tax, and we model both with her Canadian CPA. Her parents in Pune hold a PPF, which she cannot add to as a non-resident, and her Indian EPF balance needs a CA statement.
Mistakes to avoid
- Assuming a TFSA, PPF or EPF is tax-free in the country where you now live.
- Contributing to an RRSP when you have no Canadian taxable income to deduct against.
- Forgetting that some retirement plans still require an FBAR or Form 8938 review.
- Using last year's limit; the IRS and CRA change limits annually.
- Withdrawing a foreign plan without checking local penalties and both countries' tax.
How we can help
Our Aurora, Illinois firm reviews each account's U.S. treatment, completes the reports and coordinates with your Canadian CPA and Indian CA so withdrawals and contributions are consistent across countries. See cross-border tax services, relocation and immigration tax planning and the retirement and savings glossary. More three-country tables are on the comparisons hub.
Frequently asked questions
What is the 2026 401(k) limit?
$24,500 for employee deferrals, according to the IRS, up from $23,500 in 2025.
What is the Canadian RRSP limit for 2026?
$33,810, or 18% of the prior year's earned income if that is lower.
Can an NRI open a PPF account?
No. The government's PPF scheme rules say NRIs are not eligible to open a new account.
Can I contribute to a TFSA after moving to the U.S.?
That depends on Canadian residency rules, and contributing is usually unwise from a U.S. tax view. Check with your Canadian CPA and us before you contribute.
Does the U.S. recognize the NPS?
The U.S. has no special rule for it. Treatment depends on the plan's facts, and the reporting rules apply.
Official sources
- IRS: 401(k) limit increases to $24,500 for 2026, IRA limit to $7,500
- CRA: MP, RRSP, DPSP and TFSA limits, YMPE
- CRA: RRSPs and other registered plans for retirement (T4040)
- PIB: Employees' Provident Fund scheme
- PFRDA: NPS All Citizen Model
- National Savings Institute: Public Provident Fund scheme
This page summarizes public guidance in plain language. If anything here differs from the official source, the official source controls.
General information only. It is not tax, legal, accounting or immigration advice for your situation, and rules change; confirm the current rules with the official source or a licensed professional in the relevant country.