Search found 5 matches
- Thu Apr 22, 2021 6:07 am
- Forum: Canada / United States Tax & Accounting
- Topic: Dual Citizen, Capital Gains on US stocks
- Replies: 8
- Views: 2709
Re: Dual Citizen, Capital Gains on US stocks
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. You ...
- Tue Apr 20, 2021 5:14 pm
- Forum: Canada / United States Tax & Accounting
- Topic: Dual Citizen, Capital Gains on US stocks
- Replies: 8
- Views: 2709
Re: Dual Citizen, Capital Gains on US stocks
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.
- Tue Apr 20, 2021 10:44 am
- Forum: Canada / United States Tax & Accounting
- Topic: Dual Citizen, Capital Gains on US stocks
- Replies: 8
- Views: 2709
Re: Dual Citizen, Capital Gains on US stocks
I'm going to take your advice - just wanted the Treaty reference. thanks again!
- Tue Apr 20, 2021 2:10 am
- Forum: Canada / United States Tax & Accounting
- Topic: Dual Citizen, Capital Gains on US stocks
- Replies: 8
- Views: 2709
Re: Dual Citizen, Capital Gains on US stocks
Is Treaty XXIV (6) the re-sourcing rule that you refer to? https://www.irs.gov/pub/irs-trty/canada.pdf
- Mon Apr 19, 2021 5:26 am
- Forum: Canada / United States Tax & Accounting
- Topic: Dual Citizen, Capital Gains on US stocks
- Replies: 8
- Views: 2709
Dual Citizen, Capital Gains on US stocks
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 wer...