Serbinski Accounting Firms

New IRS rules related to the Transition Tax in IRC 965 make it unattractive for any US person to accumulate retained earnings with a foreign corporation, and the transition tax retroactively taxes retained earnings back to 1986. Here are some references: https://serbinski.com/treatment-deferred-fore...

The Internal Revenue Service has upheld the notion that common law marriages are recognized for purposes of filing a joint return (for over 50 years). In Revenue Ruling 58-66 the Service says: "In Revenue Ruling 58-66, the Service stated that a couple would be treated as married for purposes of...

Here is a recent article from CBC:

http://www.msn.com/en-ca/money/topstori ... ocid=ientp

We generally take the position that everything about our financial lives is publicly known, and recommend that you file returns on that assumption.

With the introduction of the Tax Cuts and Jobs Act, tax filing rules for 2018 have substantially changed.

We have outlined some of the major changes here:

https://serbinski.com/2018-tax-cuts-and ... al-changes

One further advantage of US citizenship is that tax free transfers between spouses on death are only available if both spouses are U.S. citizens.

Generally, a stock of a listed corporation would not be a PFIC.

A bank conducts the active business of borrowing and lending, and is thus not engaged in passive activities.

The definition is intended to classify pooled investment situations, mutual funds and similar investment vehicles as PFIC's.

Also, if you elect to file a joint return with your non US citizen wife, you would need to include all FBAR filings etc. for her. Sometimes this election is helpful when "married filing separately" gives rise to AMT. If you do file MFS, you may also find that even if you include all of the...

NOTE: Your return in the U.S. will depend on the overall time spent in the U.S. in any 12 month period. If you spend over 183 days in the U.S., you may also be considered a resident of the U.S., and this will mean that you will file in the U.S. in the same way as a U.S. resident. Your tax due and th...

Although there may not be specific penalties for failure to file form 8621, a US return is not considered complete unless all required forms are filed. This may mean that the statute of limitations would not close the return after three years as in the case of complete returns, and civil penalties c...

Even though the institution calls this a "deposit account" for U.S. purposes, any TFSA is still a foreign grantor trust. You, as the trustee and grantor, establish a trust which is has certain tax attributes associated with it, but only as long as the funds remain within the trust. If the ...

You can try:

Darrell Thompson

Darrell.Thompson@macquarie.com

The "Certifying Acceptance Agent" program has effectively been suspended, and any W7 application must now include identification data certified by the issuer. In the case of Canadians, this means that you need to visit passport Canada to have them issue a certified copy of your passport fo...

This new development is true.

However, there is another way to satisfy the documentation requirement, and that is to provide a copy of your passport certified by the issuing agency.

This is a free service.

See our site under "working in the USA" for details.

IRS has relaxed their view of U.S. citizens or Dual citizens who live outside the U.S. In FS-2011-13, IRS states that taxpayers who owe no tax due to the application of foreign tax credits or foreign earned income exclusions will not be assessed failure to file or FBAR penalties in cases where IRS h...

Note: We have had IRS requests for SS-4 forms for Canadian trusts filing 3520/3520A forms. In many cases, IRS assigns the EIN and then asks for the SS-4.

We have taken the position that we will submit an SS-4 with any new 3520/3520A filing for TFSA or RESP accounts.