The Canada-U.S. Totalization Agreement
The Canada-U.S. Totalization Agreement assists individuals who have worked in both countries. Its purpose is to prevent paying Social Security taxes to both nations on the same income and to help those who haven't earned enough credits in one country to qualify for benefits by counting work from both.
How Credits are Totalized
If you lack sufficient U.S. work credits (40 quarters) to qualify for Social Security, the U.S. Social Security Administration may count your CPP coverage periods to help you meet the minimum requirement. You need at least six quarters of U.S. coverage to use this totalization. Once eligible through totalization, your U.S. benefit amount is calculated based only on your U.S. earnings history, resulting in a partial benefit.
The Repeal of the Windfall Elimination Provision (WEP)
Previously, the Windfall Elimination Provision (WEP) reduced U.S. Social Security benefits for those receiving a pension from work not covered by Social Security, including many foreign pensions like CPP. However, the Social Security Fairness Act, enacted in January 2025, repealed both the WEP and the Government Pension Offset (GPO). This means your CPP pension will no longer reduce your U.S. Social Security benefit, and eligible individuals may receive retroactive payments.
Coordinating Your Benefits: CPP and Social Security
With the WEP and GPO repealed, coordinating your benefits involves applying separately for CPP through Service Canada and Social Security through the U.S. Social Security Administration.
When to Apply for Benefits
- CPP: You can start collecting a reduced benefit at age 60, a full benefit at 65, or an increased benefit by deferring until age 70.
- Social Security: Benefits can start as early as age 62 with a reduction. Your full retirement age depends on your birth year, and delaying until age 70 maximizes your monthly payment.
Coordination Strategies
Timing is key when claiming benefits. Consider these strategies:
- Start Social Security Early, Delay CPP: This provides earlier income while allowing your CPP to grow.
- Delay Social Security, Start CPP Early: With WEP gone, delaying Social Security increases that benefit while you receive earlier CPP payments.
- Delay Both Benefits: If financially feasible, delaying both until age 70 yields the highest possible monthly income from both sources.
Navigating the Application Process
Applying for CPP and Social Security are separate processes. If you live in the U.S. and need to apply for CPP, a U.S. Social Security office can provide forms and submit your application to Service Canada. Canadian residents can apply for U.S. benefits through a U.S. Social Security office near the border or a Service Canada Centre.
How to Apply for CPP and Social Security
To apply, gather personal identification, work history, and contribution records for both countries. Contact the appropriate agency (U.S. Social Security Administration or Service Canada) and complete the necessary application forms, such as Form CDN-USA 1 for cross-border applications. If you are using totalized credits, ensure the agency is aware of your contributions in the other country.
Potential Tax Implications
Benefits from both countries are generally taxable income. The U.S.-Canada tax treaty addresses how these benefits are taxed to prevent double taxation. U.S. Social Security benefits paid to Canadians may have U.S. tax withheld, for which a credit might be claimed on your Canadian return. CPP benefits paid to U.S. residents are typically taxable in the U.S. Consulting a cross-border tax advisor is recommended.
A Comparison of Key Differences
| Feature | Canada Pension Plan (CPP) | U.S. Social Security |
|---|---|---|
| Primary Eligibility | At least one valid contribution to the plan. | 40 credits of work (typically 10 years). |
| Totalization Agreement | Use U.S. credits for eligibility if needed (for OAS only, not CPP itself). | Use Canadian credits for eligibility if needed. |
| Earliest Collection | Age 60 (reduced benefit). | Age 62 (reduced benefit). |
| Full Retirement Age | Age 65. | Varies by birth year (66-67). |
| Maximum Deferral | Age 70 (increased benefit). | Age 70 (increased benefit). |
| Funding | Contributory, funded through employee and employer contributions. | Contributory, funded through payroll taxes. |
| WEP/GPO Impact | No reduction to CPP. Previously reduced some U.S. benefits (repealed). | Previously reduced by non-covered pensions (repealed). Benefit amount can be impacted by international agreements. |
Conclusion
Thanks to the Canada-U.S. Totalization Agreement and the repeal of WEP and GPO in 2025, receiving both CPP and Social Security is now more feasible and financially advantageous for individuals with work history in both countries. The process requires applying separately to each agency and strategizing the timing of claims to maximize overall retirement income. Seeking advice from a cross-border financial and tax professional is highly recommended to develop a comprehensive retirement plan. For more information on U.S. Social Security, visit the Social Security Administration website.