Technical article

Does the US Have a Tax Treaty With Your Destination? Canada, Jamaica and Mexico

Does the US have a tax treaty with each place, and what does it say about pensions?

By Neil Solomon · 4 min read

Picture a couple named Mark and Elaine. Both are 63. Between them they have Social Security, one employer pension, and an IRA. They are looking at Canada, Jamaica and Mexico. They ask one thing. Does the US have a tax treaty with each place, and what does it say about pensions?

I read the treaty texts that the IRS hosts. They answer part of the question. I will show what they say, and then what they leave open.

The short version

What the saving clause says

Jamaica and Mexico both have the clause. In the words returned:

"a Contracting State may tax its residents ... and by reason of citizenship may tax its citizens, as if this Convention had not come into effect."

This lets the US tax its own citizens wherever they live, with a short list of exceptions. For Mexico, the list includes the social security paragraph. The IRS publication on the Canada treaty states: "you still have to file a Form 1040 and report your worldwide income."

Canada: two official pages side by side

The treaty text as returned says social security paid by one country to a resident of the other, or to a US citizen, "shall be taxable only in the first-mentioned State."

The Canada Revenue Agency's page on line 31400 (dated 2026-01-20) lists "Foreign pensions (including US Social Security)" under line 11500. It says foreign pension income tax-free in Canada because of a treaty does not qualify for the pension income amount, and that income from a US IRA does not qualify either. The federal amount for 2025 is the lesser of CAD 2,000 or a worksheet amount.

I show both and do not pick. An accountant or lawyer who works with Americans abroad could say how they fit together for you.

Jamaica

Article 19 says private pensions are taxable "only in that State" unless the work was done in the other country. Annuities follow the residence state, with an exception if the annuity was bought in the other country while the person lived there. Jamaica's own tax administration page on how it treats a foreign pension is not among the sources, so its domestic rule is not given.

Mexico

Article 19(1)(a) reads as taxable "only in that State," the state of residence, for pensions from past employment. Article 19(1)(b) covers social security and public pensions, and the text returned says they are taxable only in the paying state. An official Mexican page (the tax authority is not among the sources, SAT) on how it treats a US pension, so the Mexican side is not stated.

What is left open

• How Canada, Jamaica or Mexico taxes a US 401(k) or IRA withdrawal in practice.
• Mexico's and Jamaica's own rules for a foreign pension, from their tax authorities.
• Canada's treaty text with every protocol in one place.
• The Dominican Republic and other destinations. They are left open.
• The IRS page that lists all treaties failed to load once, so I used each country's own page.