Search found 42 matches

by taxquestions
Mon Feb 21, 2022 2:56 pm
Forum: Canada / United States Tax & Accounting
Topic: RRSP non resident withdraw
Replies: 3
Views: 1158

Re: RRSP non resident withdraw

I may be able to squeeze this in on an off year, but If I am reading correctly, electing 217 would require I file a NR return with Canada for the next 5 years minimum.
by taxquestions
Sun Feb 20, 2022 10:28 pm
Forum: Canada / United States Tax & Accounting
Topic: RRSP non resident withdraw
Replies: 3
Views: 1158

RRSP non resident withdraw

I got 50k CAD in my RRSP. I live in the states and want to collapse my RRSP and transfer the funds to the states. I can either pay a 25% withholding lump sum, or if I am understanding correctly, file an section 217 and pay taxes as a non-resident which would almost completely fall in the lowest 15% ...
by taxquestions
Fri Mar 05, 2021 6:02 pm
Forum: Canada / United States Tax & Accounting
Topic: Departing Canada, fiscal year end
Replies: 1
Views: 1218

Re: Departing Canada, fiscal year end

1. Did some research. For an individual, it would be in ITA subsection 128.1(4)(a.1) it would deem your year end to be at the time you became a non resident of Canada. So from my understanding my fiscal year end is the day I depart. 2. I continued to conduct business in Canada with no PE, as a US so...
by taxquestions
Wed Mar 03, 2021 2:18 pm
Forum: Canada / United States Tax & Accounting
Topic: Departing Canada, fiscal year end
Replies: 1
Views: 1218

Departing Canada, fiscal year end

When one emigrates Canada, does their sole-prop T2125 fiscal period end on their departure date, or is it still on 12/31?
by taxquestions
Sat Feb 20, 2021 6:51 am
Forum: Canada / United States Tax & Accounting
Topic: US Tax treaty question
Replies: 4
Views: 2034

Re: US Tax treaty question

Not sure if 8833 is even required here. I dont appear to be overriding IRC code by taking this election to cost-up my inventory basis via the US-CANADA tax treaty
by taxquestions
Thu Feb 18, 2021 5:35 pm
Forum: Canada / United States Tax & Accounting
Topic: US Tax treaty question
Replies: 4
Views: 2034

Re: US Tax treaty question

Looks like the deemed dispostion would only be exempt if I retain a PE (which I am not) so I would be subject to the depature tax. It looks like id file Form 8833 and elect Article XIII(7) of the U.S.-Canada treaty. But I am unsure if this would be allowed for business inventory and how it would flo...
by taxquestions
Thu Feb 18, 2021 6:10 am
Forum: Canada / United States Tax & Accounting
Topic: US Tax treaty question
Replies: 4
Views: 2034

Re: US Tax treaty question

Interesting. Business inventory is exempt from deemed disposition if: "the business is carried on through a permanent establishment in Canada" I am unsure if this exclusion means the business had: A) A PE prior to departure, or B) Retained their PE after departure What do you think? https:...
by taxquestions
Wed Feb 17, 2021 7:31 am
Forum: Canada / United States Tax & Accounting
Topic: US Tax treaty question
Replies: 4
Views: 2034

US Tax treaty question

If one emigrates Canada you are subject to departure tax on all assets at FMV. Example, 100k basis property, 150k FMV = 50k capital gain. This could result in double-taxation if you were to sell this at a later year as a US citizen/resident as the basis would still appear to be 100k. Article XIII(7)...
by taxquestions
Wed Feb 17, 2021 1:09 am
Forum: Canada / United States Tax & Accounting
Topic: Foreign tax
Replies: 1
Views: 957

Foreign tax

Are departure taxes on business inventory by a foreign country deductible as a business expense on my Schedule C?
Example, Jan 1st I depart Canada and move to USA. Canada hits my sole prop with a departure tax (capital gain) on my inventory FMV.
Is this a deductible?
by taxquestions
Mon Feb 15, 2021 11:34 pm
Forum: Canada / United States Tax & Accounting
Topic: T2061A question
Replies: 0
Views: 7935

T2061A question

1. How aggressive is the CRA with the FMV of property for deemed disposition on form T2061A?

2. Would a 1:1 basis to FMV raise audit flags?
by taxquestions
Mon Feb 15, 2021 1:43 am
Forum: Canada / United States Tax & Accounting
Topic: Regulation 105 Withholding Tax
Replies: 0
Views: 8199

Regulation 105 Withholding Tax

US LLC, with no Canadian PE. I sell goods from a Canadian warehouse (amazon.ca). I have a BN. Question: 1. Does reg 105 apply to goods sold or only services? Do I still have to apply for a waiver? 2. Would I leave SCH 91 line 195 "Has the corporation applied for a waiver of the withholding requ...
by taxquestions
Thu Feb 11, 2021 4:11 am
Forum: Canada / United States Tax & Accounting
Topic: Deemed disposition of business inventory
Replies: 1
Views: 1131

Re: Deemed disposition of business inventory

Tried to keep it as short as possible, was hoping for some nelsona knowledge!
by taxquestions
Sun Feb 07, 2021 5:06 am
Forum: Canada / United States Tax & Accounting
Topic: Deemed disposition of business inventory
Replies: 1
Views: 1131

Deemed disposition of business inventory

•My 2020 return will be a single day (Jan 1st). •inventory cost basis on departure is $17k •Primary ties & most secondary ties severed. •After emigrating, sole-prop will continue under the same BN (Business Number), but now US based (no CDN permanent establishment) I will: •Enter T1 departure da...
by taxquestions
Fri Jan 29, 2021 11:06 pm
Forum: Canada / United States Tax & Accounting
Topic: Self-employment tax totalization agreement for partial year residency
Replies: 1
Views: 1140

Self-employment tax totalization agreement for partial year residency

Say I made 175k USD in 2020. I was a resident of Canada for Q1, and a US resident for the rest of the year. Im a dual citizen. I earned 25k USD while a resident of Canada (Q1 2020) and paid Canadian income taxes on this 25k. I will claim this on Form 1116 for a FTC (foreign tax credit). Question: On...
by taxquestions
Wed Jan 20, 2021 2:48 am
Forum: Business & Personal Immigration to Canada
Topic: 1120S Shed K "Foreign Transaction"
Replies: 1
Views: 9063

1120S Shed K "Foreign Transaction"

https://www.irs.gov/pub/irs-pdf/i1120s.pdf https://www.irs.gov/pub/irs-pdf/f1120s.pdf On the 1120S Schedule K "Foreign Transactions" line 14 confuses me. Some of my income is foreign sourced (e-commerce). Is filling this section required? Or only if I am requesting foreign tax credits or o...