u/AspenBrick12

Wanted to see how other high income US citizens in Canada are approaching investing. I'm also doing consults with some fee only CFP.

My situation

• In AB
• My (US citizen and Canadian PR) income this year: $400k CAD
• My spouse (Canadian citizen and non-US person) this year: $130k CAD
• All registered accounts maxed for both
• For me, only my RRSP holds PFIC, all else is US listed ETF
• I pay all expenses and my spouse invest all earnings

Question

• We still have cash accumulating and I want to continue investing. My thought is I just invest in a non-reg account in my name in non-PFIC ETF and deal with the US NITT tax. Is this the "best" path?

Comments

• CRA spousal/prescribed rate loan, where I lend my spouse $X dollars at a CRA set interest rate, feels risky in terms of how US may perceive so for now avoiding
• US allows gifting of ~$190k USD to a non-US spouse but spouse can't invest in non-registered account in Canada and it be taxed at their income without doing first bullet
• ^^^ If I give my spouse say $100k CAD and they invest in their non-reg account and I pay CAD tax on this as per attribution, will I be subject to the NITT on US taxes or do I just report as income?