Search found 15 matches

by oakweather
Sat Apr 17, 2021 8:32 am
Forum: Canada / United States Tax & Accounting
Topic: Canadian subsidiary
Replies: 3
Views: 363

Re: Canadian subsidiary

No, it's not intended to be CCPC, we understand that. We're interested in learning the required informational or tax filings on both sides of the border and their approximate total cost per year. For example, in the U.S., I believe Form 5471 is required that can be quite intrusive (maybe a few hours...
by oakweather
Fri Apr 16, 2021 9:10 am
Forum: Canada / United States Tax & Accounting
Topic: Canadian subsidiary
Replies: 3
Views: 363

Canadian subsidiary

Is anyone here versed in cross-border corporate tax? We are a U.S. Delaware C corporation interested in setting up a fully owned Canadian subsidiary corporation to conduct R&D activities in Canada. The Canadian corporation is not expected to generate a significant profit (revenue/grants minus re...
by oakweather
Mon Apr 05, 2021 10:47 pm
Forum: Canada / United States Tax & Accounting
Topic: Question about U.S. employer paying Canadian consultant
Replies: 1
Views: 266

Question about U.S. employer paying Canadian consultant

My employer, a Delaware C corporation, has no Canadian payroll, branch, or presence. The Delaware Corporation would like to engage a consultant who lives in British Columbia and will be conducting the work in BC (outside of the U.S.). We received contradictory advice. We were advised by someone that...
by oakweather
Tue Mar 16, 2021 10:52 am
Forum: Canada / United States Tax & Accounting
Topic: urgent help needed on 5471
Replies: 3
Views: 340

Re: urgent help needed on 5471

Also, closing the company or disposing of company stocks for the purpose of avoiding filing 5471 will not absolve you of the requirement of filing 5471, according to IRS guidelines.
by oakweather
Tue Mar 16, 2021 9:29 am
Forum: Canada / United States Tax & Accounting
Topic: urgent help needed on 5471
Replies: 3
Views: 340

Re: urgent help needed on 5471

I am not an accountant and you should seek professional advice, but I have filed 5471s before myself. Whether you need to file 5471 will depend on whether you're classified as one of the Category Filers -- see IRS Form 5471 instructions. For example, if in a year you acquire more than 10% of the com...
by oakweather
Thu Jan 28, 2021 9:00 am
Forum: Canada / United States Tax & Accounting
Topic: US Taxation of Roth Overcontribution
Replies: 11
Views: 1196

Re: US Taxation of Roth Overcontribution

Another perfectly legal way to overcome this Roth overcontribution problem is to do something called the "backdoor Roth". You contribute the money first into a traditional IRA (which may not be limited the same way as Roth is due to your filing status). Then you do a traditional-to-Roth co...
by oakweather
Tue Nov 17, 2020 7:34 am
Forum: Canada / United States Tax & Accounting
Topic: RESP for Canadian/US dual citizen beneficiary
Replies: 8
Views: 790

Re: RESP for Canadian/US dual citizen beneficiary

I am most definitely not an accountant or tax lawyer. But my understanding is that FBAR, 8938, etc. are normally for account holders or those with signatory power over the account to file (e.g. parents). I do not believe that your daughter currently holds the RESP account. As long as the account hol...
by oakweather
Sun Nov 15, 2020 7:58 am
Forum: Canada / United States Tax & Accounting
Topic: RESP for Canadian/US dual citizen beneficiary
Replies: 8
Views: 790

Re: RESP for Canadian/US dual citizen beneficiary

to clarify: the information in the link above may not exactly help in your case, but it may make some of your questions moot
by oakweather
Tue Oct 20, 2020 7:16 am
Forum: Canada / United States Tax & Accounting
Topic: Question about income source from NSERC postdoctoral fellowship
Replies: 14
Views: 1245

Re: Question about income source from NSERC postdoctoral fellowship

Just for the sake of completeness of this discussion based on additional research (though again, I'm no tax lawyer) - Non-residents of Canada are taxable on the various incomes as listed in the Canadian Income Tax Act Subsection 115(1). Of this list, neither research grants (56(1)(n)) nor scholarshi...
by oakweather
Sun Oct 18, 2020 10:06 pm
Forum: Canada / United States Tax & Accounting
Topic: Question about income source from NSERC postdoctoral fellowship
Replies: 14
Views: 1245

Re: Question about income source from NSERC postdoctoral fellowship

Thanks. As per Bubba Gum's suggestion, I studied 3.88-3.89 (S1-F2-C3), as well as the original legal language in Subsection 115(2). If I understand the language correctly, I don't think it's saying much in my case. The non-resident of Canada receiving the income source from a Canada person would, by...
by oakweather
Sun Oct 18, 2020 7:26 am
Forum: Canada / United States Tax & Accounting
Topic: Question about income source from NSERC postdoctoral fellowship
Replies: 14
Views: 1245

Re: Question about income source from NSERC postdoctoral fellowship

Thank you for all the lively discussion above! Based on the discussion, is it fair to state the follows: If the postdoctoral fellowship income appears on Box 104 of T4A, then it is categorically considered employment income? (which in my case would be U.S.-source) And if it appears on Box 105 of T4A...
by oakweather
Fri Oct 16, 2020 4:38 pm
Forum: Canada / United States Tax & Accounting
Topic: Question about income source from NSERC postdoctoral fellowship
Replies: 14
Views: 1245

Re: Question about income source from NSERC postdoctoral fellowship

Thank you for the clarification. One further question - I believe that this postdoctoral fellowship is specifically reported on Box 105 of T4A (which goes on line 13010 - scholarships, fellowships, bursaries, and study grants) rather than on Box 104 (which would otherwise go on line 10400 - research...
by oakweather
Thu Oct 15, 2020 1:09 pm
Forum: Canada / United States Tax & Accounting
Topic: Question about income source from NSERC postdoctoral fellowship
Replies: 14
Views: 1245

Question about income source from NSERC postdoctoral fellowship

I am a U.S. resident (dual U.S./Canada citizen) receiving a Canadian federal (e.g. SSHRC/NSERC/etc.) postdoctoral fellowship. I will be performing the work associated with the fellowship while living in the U.S. (I do not plan to move to Canada, or at least not in the initial phase of the fellowship...