Serbinski Accounting Firms

Yes

As long as you and your family move to US, you will no longer be taxable in canada on non-Cdn income.

there is no need to overly inconveneience yourself to divest yourself of all assets. The US treaty covers you if you and spouse move to US. The verbage on CRA site dels more with those moving to a ...

The grandparent route is also the best way for Cdns moving to US to use RESP for their kids.

It doesn't work if your kids are already in US before the paln is started, but if the grandparents start it before the kid leaves, they cab continue funding it.

This would likely work.

It won't be market value. Rememebr that the 'bump up' provision for deemed dispositions, in effect since sept 2000 only applies to investments that are subject to deemed disposition. RRSPs are not, so this portion does not apply.

There could be a biggewr issue for RRSPs: IRS could now take the ...

While the treaty offers protection from such taxation, such protection must be requested, thru W8BEN. It does indeed happen all to frequently that RRSP are withheld.

http://forums.canadianbusiness.com/thread.jspa?threadID=7679&tstart=0

As I said, once withheld, reversing this withholding is very ...

new paragrapph 7 does NOT take anything away from Roth, since this para already existed and was meant for RRSps.

While it could be applied to Roth the big difference between roths and rrsps is that US does NOT treat Roth withdrawals as income, while Canad does include RRSP withdrawals as income ...

My quick take on new Roth treatment;

Roth becomes a pension, and thus will be taxed in canada to the extent that it is taxed in US, that is none.

The language addressing Roths specifically refers -- I believe -- to the funding of a Roth by a Cdn resident. Such funding would NOT be sheltered ...

It would be on the generated income, just like any other account. No account is ever taxed based on 'increase annual value'

529 makes sense if you are planning to stay in US. Even if your child studies in Canada you will pay no tax on any 529 money while YOU live in US.

If you aren't planning to ...

6 years is the rule of thumb.

Of course, actually determining what portion of your RRSP is not taxable is going to be quite difficult if you have not been tracking for all this time...

First, you have to determine what you actually owe to Canada. It should not be the 25% once you send in your 216 return.

What ever tax you do end up paying and owing in 2006 will be available for use as either a foreign tax credit (against the net income your rental produces on your US return), OR ...

No. They must do it.

Currently 529 are not 'sheltered' in Canada, thus no tax is due on taking the money, since tax would be paid all along (in your hands) during the time it was held.

So, no tax at the end, but tax all the time you are in Canada.

As I pointed out then, 8223 is for those exempt from withholding for work performed in US. Some firms don't make the distinction, and some firms withhold even when they aren't supposed to (after all didn't your firm send you a W-9?) In such cases it may be necessary to use 8223 to hammer the point ...

W-8BEN