Serbinski Accounting Firms

As I said, the only thing that your donor has to watch for is gift limits. But as to gifting stock to a foreign person, there are no US cap gains issues.

Your spouse gifting to you would still make it finally taxable in spouse's hands, by the attribution rules, with the cost basis of the day your ...

Neither the donor nor your non-US spouse would be subject to any US cap gains tax. There may be gift tax issues for the donor if the donation is more than a certain amount. The spouse would owe cap gain in canada when sold based on the value when it received.

For you, you would inherit the original ...

1. Yes, a second NR4 from that property.
2. Yes, if your actual tax on that property would be less than 25% of the gross (which it very likely is) it would be to your advantage

You will need to apply a second NR6 (or more likely a revised NR6) with the new property

Remember that all rental income ...

That is not the case as they were formed as essentially an employee benefit and are protected by treaty.
You would only report income if you made a non-medical withdrawal (as you would in US)>

Where did you read this? Not here I hope,

If you file as a resident, then yes you will need to report internal incomes from those accounts REGARDLESS of whether you are required to file a FATCA report.
You are not required to file a 1040, you could both be filing 1040NR under XXV(3), and avoid all this.

First, to clarify, the HSA would be sheltered. It is simply the contributions would not be deductible. But other than that, it works like any other HSA.

Your HSA does not have to be reported to CRA. For your Roth, I would simply send in the election that you should have sent the first year in ...

Just to clarify, Bank interest from Canada paid to US residents is not taxed in Canada, not because it is being reported in US, but only because Cdn regs (and the treaty) say so.

There is no rule that says one doesn't have to report income in one country "since it is claimed elsewhere". The poster ...

It is safest to report these accounts (all of them, including your Cdn bank accounts) on FBAR. Whether they need to be filed under FATCA depends on the total value of your foreign (ie. Cdn assets).
There is some debate whether you are required to file FBAR or FATCA when you have merely ELECTED to ...

Ignoring the (non-answer) responses to your question posted elsewhere, your spouse will need an SSN (it will be a non-working SSN) to collect, and it will be issued during the application process. They will fill the SSA-2 form to get things rolling (when they fill with ID/citizenship. Age and ...

Just so we are clear, the RRIF is actually disposed, not "deemed", since it was paid out.

The RRIF becomes part of his estate, subject to estate tax. Any Cdn tax would be used against any US estate tax that would arise, but the estate tax exemption is so large that it is unlikely that there would ...

I would forget about this. CRA wouldn't bother going back more than 6 year AT MOST.

A. The Cdn tax on dividends can only be used on passive income. Any past or current tax on RRSPs or other general income can be used towards your US tax obligations on your RRSP and CPP income.

B. You can. A better option would be to reduce your RRSP tax, by converting to a RRIF.

C. From what you ...

1, Yes, You CAN use past foreign tax under the general limitation category, carried forward from previous years.
2. No, CDn payor MUST withhold 25% of the RRSP withdrawal . Only a RRIf can be withheld at 15%, and even then only if you are taking relatively small ammounts (ie. less than 10% per year ...

you should still follow the RP, and prepare the documentation (including the original 8833) you would have made at the time of the election. Then simply refer to the article when selling each investment on your deemed disposition list.

You should still attach the 8833 that you would have prepared back then, each year that you sell any of the investments that were deemed sold, using as your cost basis the value determined in the year you moved.

While RP-10-19 outlines a convenient way for both the taxpayer and the IRS to track ...