Taxes

Should Canadians Claim CCA on a US Rental Property?

The standard advice is no, don't claim it on a property you expect to appreciate. I disagree, and here is the actual math on a real house. The cash difference in total tax paid over ten years is about C$621. But what you give up by not claiming is a decade of liquidity.

Should a Canadian claim capital cost allowance on a US rental property, and what the math actually shows
In pure cash it is close to a wash. What it buys you is the ability to absorb a shock.
Read this first. I am a property investor, not an accountant. The figures below are modelled on a real property and I have shown the workings. Whether CCA suits your own position depends on your tax bracket now, your bracket when you sell, and what you would do with the money in between. Take advice from a cross-border CPA.

Canada lets you claim capital cost allowance on a rental building. Class 1, 4% a year on a declining balance, with half rates in the first year.

Unlike US depreciation, it is optional. Nobody makes you claim it. The American side works quite differently. They will charge it back to you when you sell whether you claimed it or not, and I have set that out in the US tax guide for foreign property investors.

And the standard advice you will read almost everywhere is: do not claim CCA on a property you expect to appreciate. The reasoning is that Canada recaptures it at your full marginal rate when you sell, which is harsher than the American rule, so you are just deferring the tax and possibly making it worse.

That reasoning is mathematically correct and I still think it is wrong. Here is why.

Key takeaways

  • CCA is optional in Canada. US depreciation effectively is not.
  • Claiming it on a real $85,000 house cut the ten year Canadian tax bill from C$18,736 to C$6,283.
  • But the recapture on sale came to C$13,030, so in pure cash it is a wash. About C$621 worse off.
  • That C$621 is the wrong number to optimise.
  • Invest the saving and the breakeven return is only 0.89%.
  • Hold it in cash at 4% and by year three you can replace a furnace without borrowing.
  • Unlike the US, CCA does not reduce your cost base, so the capital gain is unaffected.
  • It cannot create or increase a rental loss, which genuinely restricted it in one year.

What CCA is worth

Let me show you my reasoning using a real property. A Kansas City rental bought in August 2016 for $85,000, held for ten years, and worth about $145,000 today. It is the same house I use in my case study on selling a US rental as a Canadian, where the full ten year model lives.

To be clear about that house: I do not own it, and the sale I model is hypothetical. It is a real property with a complete public record, which is why I picked it.

First, land is not depreciable in either country, and the building portion of the purchase price was $68,000. So that is the amount we are depreciating.

Then, to be clear about how I arrived at the property's current value, I am helping a client purchase a rental a couple of blocks away that we have just had appraised.

At 4% on a declining balance, with the half year rule in 2016, that produces about $21,850 of CCA over the decade to 2026.

A little less than the US depreciation on the same house, which came to $24,727. That is because 4% on a declining balance, which is Canada's rule, is slower than straight line over 27 and a half years, which is the IRS rule.

One thing to remember. CCA cannot create or increase an on-paper loss the way US depreciation can. You can only claim CCA up to the amount of your net rental income from that property, before CCA, not your taxable income generally. If more is available in a given year, you cannot use all of it. On this property that cost $256 in 2017, when the available CCA exceeded that year's net rental income. Small, but worth being aware of.

What it saves. Claiming CCA cut the ten year Canadian income tax bill from C$18,736 to C$6,283. A saving of C$12,409.

Then Canada takes it back

On sale, the CCA is recaptured and added to your income.

And Canada recaptures it at your full marginal rate. Not at a capped 25% like the United States. So there is no rate arbitrage here, only timing.

On this property, C$30,016 of CCA claimed over ten years would be taxed at 43.41% for a higher rate payer, which is C$13,030 added to your final tax bill on exit.

The pure cash position over ten years. Amounts in parentheses are deducted.
Canadian income tax saved over ten yearsC$12,409
Recaptured on sale(C$13,030)
Net, in pure cash(C$621)

Which is exactly where the standard advice comes from. Pretty much a wash, and very slightly negative. So why bother?

Two differences from the American rules

Before the answer, two mechanics worth knowing, because people assume CCA and US depreciation work the same way and they do not.

CCA does not reduce your cost base. In America, depreciation lowers your basis, which makes your capital gain bigger. In Canada it reduces the undepreciated capital cost but leaves the adjusted cost base alone.

So on sale you get two separate charges: the recapture, taxed as ordinary income, and the capital gain, worked out on your original cost exactly as though you had never claimed a penny.

On this house the capital gains tax in Canada was C$16,516 whether CCA was claimed or not.

And the recapture rate is your full marginal rate. The US caps depreciation recapture at 25%. Canada does not cap it at all. If you are at 43.41%, you claim at 43.41% and you repay at 43.41%.

On this property that difference is worth C$5,526. The same C$30,016 of recapture would cost C$7,504 under the American cap and costs C$13,030 here.

And on the American side you are charged whether you claimed it or not, which is its own trap.

That second point is why claiming CCA is a much closer call in Canada than claiming depreciation is in America.

Why the cash figure is the wrong number

Back to that C$621.

It assumes you took the money and put it in a drawer.

You had that C$12,409 for years before the recapture arrived. The 2016 saving sat with you for a decade. Put it anywhere that earns anything and the picture changes.

What the saving is worth if it earns something, against the recapture that eventually arrives. Illustrative returns, not a forecast.
If it earnsGrows to by 2026Against recapture ofNet
0%C$12,409C$13,030(C$621)
3%C$14,639C$13,030C$1,609
5%C$16,358C$13,030C$3,328
7%C$18,290C$13,030C$5,260

The breakeven return is 0.89%.

You can work out the US side of your own position with our US rental income tax calculator, then apply the Canadian treatment on top.

That is roughly a savings account. Anything with equity exposure over a decade clears it comfortably, and a plain balanced fund at 7% leaves you over five thousand dollars ahead.

So the standard advice is only right if you leave the money in cash and earn nothing on it.

The argument that actually matters

Now forget the return entirely, because there is a better reason.

That money is a reserve.

Put each year's saving into a high yield savings account at 4% and look at what it lets you do.

Each year's saving held in a high yield savings account at 4%.
YearReserveWhat it now covers
3C$3,698A water heater
5C$6,845A furnace, or a full turnover
8C$11,532A roof
10C$14,878Against a C$13,030 recapture

Read the right hand column, not the middle one.

By year three you can replace a furnace without borrowing. By year five you can absorb a heavy turnover. By year eight you can put a roof on.

The investor who paid the tax instead has the same house, the same rent and the same tenant. What they do not have is the ability to absorb a shock.

The one thing to remember: the question is not which option produces a slightly better number in ten years. It is which option leaves you able to pay for a new roof when the roof fails.

What happens the day the furnace dies

Make it concrete. Year three, the furnace goes. Call it $5,000.

If you claimed CCA, you have C$3,698 sitting there. You top it up, you pay, you are annoyed, you move on.

If you did not, your options are:

  • A credit card, which will also block your next US mortgage application, because lenders will not accept unsecured borrowing as deposit funds and will see it in your file
  • A personal loan, same problem
  • Leave it broken, which loses you the tenant, and on a voucher tenancy fails the inspection and stops the rent
  • Sell in a hurry, which is the worst price you will ever get

Every one of those is worse than the C$621 you were optimising for.

Now make it a tenant causing $20,000 of damage in year eight. Claimed CCA and you have C$11,532 towards it. Did not, and you have nothing.

On a voucher tenancy the housing authority requires the repair done promptly and is not much interested in who caused it. So it is not a choice about whether to fix it. It is a choice about where the money comes from.

All said and done, the best advice I can give any new real estate investor is to hold enough liquid reserves to absorb problems. And this is real estate. You will have problems to deal with at some point.

If you paid all that money to the tax collector instead, so you could be a few hundred dollars better off in ten years time, that is stepping over hundred dollar bills to pick up pennies.

Four things that would change my mind

I am not going to pretend this is universal. Here is when the standard advice wins.

If you will not actually reserve or invest it. The whole argument assumes the money goes somewhere useful. If it funds a holiday, you have borrowed C$13,030 from your future self at your marginal rate and bought nothing with it.

If your marginal rate will be higher when you sell. You claim at today's rate and repay at the rate in the year of sale. Move up a band in the meantime and the recapture costs more than the relief was worth.

If the recapture itself pushes you up a band. C$30,016 of extra income in a single year can easily do that. This is the sharpest version of the risk, and it argues for timing your sale in a low income year if you have any choice about it.

And if you can genuinely write a cheque for a new roof out of income without it registering, then the reserve argument does not apply to you and you should optimise the spreadsheet instead.

The bottom line

In pure cash terms, over ten years on a real house, claiming CCA left the owner about C$621 worse off. That is the number the standard advice is built on and it is accurate.

It is also almost meaningless. Invest the saving at anything above 0.89% and you are ahead. Hold it as cash and you spend a decade able to fix things.

Paying money to the government early, in exchange for a marginally better number a decade later, is a poor trade for anybody who cannot absorb a five thousand dollar repair out of income.

Which is most people, most of the time.

Remember, this is a game of probabilities. The probability that a rental property needs something expensive over ten years is close to one.

If you want to see the full ten year model this comes from, including the sale, it is in selling a US rental as a Canadian, and you can run your own numbers with the free tools in my investor starter kit.

This article is general information, not legal, tax or investment advice. David Garner is a property investor and is not a tax adviser, accountant or CPA. Cashflow Rentals is a real estate consultancy, not a tax practice or law firm. 5240 Brooklyn Avenue is a real property used as an illustration; it is not owned by the author or by Cashflow Rentals, and the sale described is hypothetical. The comparable property referred to is one Cashflow Rentals is currently helping a client to purchase, which is disclosed above. The figures are modelled using published county tax records, real letting listings and Bank of Canada exchange rates, and assume an Ontario taxpayer at a 43.41% marginal rate throughout. Your own bracket, both now and in the year you sell, will change the answer. Investment returns used to illustrate the compounding argument are hypothetical and not a forecast. Tax rules change. Always consult a qualified cross-border CPA before deciding whether to claim CCA.
Free Investor Resources

The Foreign Investor Starter Kit

Everything you'll ever need to buy and manage U.S. rental property from overseas safely and with confidence.

Open the Starter Kit
Free to browse. No jargon, no sales pitch.

Frequently asked questions

Is CCA optional in Canada?

Yes. Unlike US depreciation, which is effectively compulsory because your basis is reduced whether you claim it or not, Canadian capital cost allowance is a choice you make each year.

What rate is CCA on a rental building?

Class 1, 4% a year on a declining balance, with half rates in the year you acquire it. That is considerably slower than US depreciation, which is straight line over 27 and a half years.

Does CCA reduce my capital gain when I sell?

No, and this catches people. CCA reduces the undepreciated capital cost, not the adjusted cost base. So your capital gain is worked out on your original cost as though you had never claimed anything, and the recapture is a separate charge on top.

At what rate is CCA recaptured?

Your full marginal rate, as ordinary income. The United States caps depreciation recapture at 25%. Canada does not cap it. On the property in this article that difference is worth C$5,526.

Can CCA create a rental loss?

No. You can only claim CCA down to zero net rental income on that property, not beyond it, and not against your other income. On the property in this article that restriction cost $256 in one year, when the available CCA exceeded the rental income.

So should I claim it or not?

My view is usually yes, provided you will actually reserve or invest the money it saves. In pure cash it is close to a wash, but the breakeven return is under 1% and the liquidity it builds is worth more than the arithmetic suggests. If you would spend it, or if your rate will be higher when you sell, the standard advice is better.

Does claiming CCA affect my US tax?

No. CCA is a Canadian deduction and US depreciation is a separate American one. You claim depreciation on your US return regardless, because the IRS reduces your basis whether you claim it or not.

Terms used in this article

TermWhat it means
CCACapital cost allowance. Canada's version of depreciation, and optional.
Class 1The category covering most buildings, at 4% a year on a declining balance.
UCCUndepreciated capital cost. What is left of the building's cost after CCA.
ACBAdjusted cost base. What your capital gain is measured against. CCA does not reduce it.
RecaptureThe CCA being added back to your income when you sell, at your full rate.
Half year ruleYou claim only half the normal CCA in the year you buy.
David Garner, co-founder of Cashflow Rentals
Written by

David Garner

David is co-founder of Cashflow Rentals and a British investor who has personally purchased more than 120 U.S. rental properties as a foreign national since 2016. He helps overseas investors build U.S. rental portfolios remotely, from his base in Brazil.