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Canadian Buying Florida Real Estate — The Complete Guide

Canadians are the #1 international buyer group in Florida by dollar volume — $1.9 billion in 2025, a 52% increase from 2024. Canadian buyers are primarily lifestyle-motivated: the snowbird second home that replaces Canadian winters with Florida sunshine. The Canadian buyer’s specific issues: FIRPTA ...

Canada–US Tax Treaty Benefits

The Canada–US Tax Convention (Treaty) provides specific protections for Canadian buyers of US real estate: (1) Estate tax: the Treaty gives Canadian residents the same proportional estate tax exemption as US citizens. A Canadian resident’s Florida property is only subject to US estate tax if the proportional exemption is exceeded. For a Canadian with a $3M Florida property and a total worldwide estate of $6M: proportional US exemption = ($3M / $6M) – $13.61M = $6.8M. Since the US property ($3M) is below the proportional exemption ($6.8M), no US estate tax is owed. This treaty provision dramatically reduces the urgency of entity structuring for Canadian buyers compared to buyers from non-treaty countries. (2) FIRPTA withholding reduction: Canadian residents may apply for a reduced withholding certificate based on the treaty-rate tax on the actual gain. (3) Rental income: Canadian residents can elect to file Form 1040-NR treating rental income as effectively connected income, paying tax on the net income after deductions rather than the default 30% gross withholding.

183-day-rule

Canadian snowbird owners must track US presence carefully to avoid inadvertent US tax residency. The Substantial Presence Test: a person is a US tax resident in a year if their weighted US-day count equals 183 or more. The formula: (days in current year) + (1/3 of days in prior year) + (1/6 of days two years ago). For a snowbird spending 120 days/year: 120 + 40 + 20 = 180 — just under the threshold. For a snowbird spending 130 days/year: 130 + 43 + 22 = 195 — over the threshold. The Closer Connection Exception (Form 8840): Canadian residents who exceed the Substantial Presence Test can still be treated as Canadian tax residents if they file Form 8840 by June 15 demonstrating that Canada is their country of closer connection (primary home, family, professional licence, voter registration, most time spent). Most genuine snowbirds qualify for this exception. File it annually as a protective measure.

Financing Options for Canadians

Canadian buyers have several financing routes: (1) Canadian banks with US operations: RBC Bank USA and CIBC US specifically serve Canadian buyers of US real estate. They understand the Canadian income documentation (T4 slips, Notice of Assessment) and can approve mortgages using Canadian financial records. Down payment: typically 25–35%. (2) US foreign national mortgage programs: same as any other foreign buyer. 25–30% down payment, 12–24 months of Canadian bank statements, letter of employment or accountant letter for self-employed. (3) Canadian equity release: some Canadian buyers remortgage their Canadian property to fund the Florida purchase in cash. This avoids US foreign national mortgage complexity entirely. (4) CAD/USD conversion: use a foreign exchange specialist (Wise, OFX) rather than a Canadian bank for the currency conversion. Savings of 1–2% on a large conversion: $20,000–$60,000+ on a $2M purchase.

Top Florida Markets for Canadians

Naples / Bonita Springs / Estero ($800K–$4M+): the highest per-capita Canadian concentration in Florida. Golf community culture, Gulf access, conservative lifestyle. The Royal Canadian Legion presence in the area provides immediate social infrastructure for Canadian arrivals. Sarasota / Siesta Key ($700K–$3M+): second highest Canadian concentration. Gulf lifestyle, arts community. Palm Beach County ($600K–$3M+): Intracoastal and golf communities; established Canadian snowbird community in western Boca Raton neighbourhoods. Orlando / Kissimmee ($350K–$1.5M+): family-oriented Canadian buyers with children who visit Florida seasonally for theme park access. All four markets have established Canadian snowbird communities — the buyer is joining a peer group, not pioneering.

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Frequently Asked Questions

Do Canadians pay FIRPTA when they sell their Florida home?

Yes. FIRPTA withholding (15% of gross sale proceeds) applies to Canadian sellers. The Canada-US Tax Treaty may allow a reduced withholding certificate based on the actual treaty-rate tax on the gain. Apply to the IRS before closing.

How many days can a Canadian stay in Florida each year?

A Canadian can spend up to approximately 182 days per year in the US without triggering US tax residency under the Substantial Presence Test, provided they file Form 8840 (Closer Connection Exception) annually. Most snowbirds spend 120–150 days — well within this limit.

Can a Canadian get a mortgage for a Florida property?

Yes — through RBC Bank USA, CIBC US, or US foreign national mortgage programs. Down payment: typically 25–35%. Canadian T4s, Notice of Assessment, and bank statements are the primary income documentation.

Should a Canadian set up an LLC for their Florida purchase?

The Canada-US Estate Tax Treaty significantly reduces the estate tax urgency for most Canadian buyers. For estates below the proportional exemption threshold, personal name ownership may be appropriate. For estates above the threshold, the foreign corporation + US LLC structure provides additional estate tax protection. Discuss with a US international tax attorney.

Canadian Buyer Florida Checklist

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FIRPTA Guide — Florida Property Tax — Insurance Guide — Return to International Buyer Hub ›