Accounts in Canada, becoming USA resident alien

This is our main tax information forum which deals with topics concerning Canadians living and working in the U.S., U.S. citizens contemplating working in Canada, and all aspects of Canadian and U.S. income tax and related adminstrative issues.

Moderator: Mark T Serbinski CA CPA

Post Reply
jeff_kerr
Posts: 2
Joined: Wed Apr 13, 2016 4:37 pm

Accounts in Canada, becoming USA resident alien

Post by jeff_kerr »

Hello Canada/USA tax experts,

I am a Canadian student studying in the USA and just crossed the substantial presence limit (5 years for F1 students) as of Jan 1 2015. I wonder if you could help me in understanding USA resident alien taxes for 2015 tax year? I have done my own research, but not super confident, would appreciate your wisdom...

Bank accounts still in Canada:
(1) How do I handle foreign currency fluctuations on these deposits? The money has never been in USD so I don't really have a cost basis for it. The logic in this post makes sense to me: https://www.quora.com/Foreign-currency- ... by-the-IRS
(eg. no Forex gains/losses on money that is completely outside the USA). But there are no references and I can't seem to find the relevant IRS Pub or topic that discusses this.
(2) Going forward do I simply report interest income every year (converting CAD interest to USD)? I don't need to worry about the USD value of the CAD principal going up and down, correct? Or am I required to use the USD value on Jan 1 2015 as a basis to keep track, or some other method?
(3) What are the implications if I eventually want to bring the money into USA?

Non-registered mutual funds:
(4) This seems like a headache due to PFICs (like most, I was also late to this party).
(4a) From my reading, CDN mutual fund is a PFIC. I don't have all the information for QEF, so I think I should elect mark-to-market.
(4b) Unlike with the bank accounts (if I am correct about #2), it seems like I am required to track currency fluctuations with this.
(4c) In the first year, the cost basis is just the USD value at the beginning of the year (due to treaty, I am considered to have "bought" and "sold" on the day I left and start with a new cost basis moving forward).
(4d) Afterwards I should keep track of the increases/decreases to cost basis in USD due to distributions using the appropriate exchange rates (eg. avg. rate for the year or exact rates for distributions).
(4e) I report the distributions from (d) as income each year
(4f) And I should use the year-end FX rate to calculate current USD value (and compare with my USD basis from (d)) for the purposes of reporting on Form 8621 and claiming income (or loss) from year-to-year due to mark-to-market regime.
(4g) Does this seem correct?

RRSP:
(5) Nothing special here. I can keep it and since I am not withdrawing, I don't need to report on US taxes. Still needs to be reported FBAR.

Thanks in advance for your wisdom on some or all of these points!
Jeff
jeff_kerr
Posts: 2
Joined: Wed Apr 13, 2016 4:37 pm

Post by jeff_kerr »

Based on further reading, I think I can simplify my main confusion.

How to deal with foreign exchange rate for money left in Canada?
a) For bank account, no impact as there is no "transaction" if it stays in Canada? Also no impact if I bring to the USA at a later date?
b) For non-registered investments, need to use exchange rate on the day I left Canada to calculate USD value on that day, and keep track of USD cost basis from there for reporting as PFIC.

Thanks in advance!

Phil
Post Reply