Serbinski Accounting Firms

followup FYI for all readers: the instructions to form 1116 state

f. Certain Income Re-Sourced
by Treaty
If a sourcing rule in an applicable
income tax treaty treats U.S. source
income as foreign source, and you elect
to apply the treaty, the income will be
treated as foreign source.
Important ...

I didn't see the words "sourcing" or "re-sourcing" in the Treaty so I wondered where in the Treaty this is generally thought to reside. But if such a question isn't a good use of your time, I apologize! Your prior explanation was great and I much appreciate it.

I'm going to take your advice - just wanted the Treaty reference. thanks again!

Is Treaty XXIV (6) the re-sourcing rule that you refer to? https://www.irs.gov/pub/irs-trty/canada.pdf

I have read your past posts as well as the Treaty XIII (Gains) and XXIV (Elimination of Double Taxation). So I can see why you have advised, with respect to capital gains on stocks of US companies traded on US stock exchanges held at a Canadian broker:

in 2018: "capital gains.... since they were ...