Serbinski Accounting Firms

Are there any pitfalls to be aware of when a Canadian discretionary inter-vivos trust invests in a U.S. Limited Partnership? This L.P. will earn effectively connected income and it is the intention that the Cdn. trust will be the taxable entity filing the U.S. returns, as opposed to the individuals ...

What about the threat that the IRS will deny deductions and impose tax on gross income when returns are not timely filed?

Cory

A nonresident taxpayer has owned an interest in a U.S. limited partnership for several years. He hasn't filed 1040NR's as he understood he was not required to file with only losses to report. Now he has income in 2003 and since most of the returns are over the 16 month deadline, the unallowed passiv...