Search found 16013 matches

by nelsona
Sun Jan 26, 2020 6:49 am
Forum: Canada / United States Tax & Accounting
Topic: How to calculate OID on C$ bonds
Replies: 2
Views: 14

Re: How to calculate OID on C$ bonds

First, do realize that in US you are not obligated to report accrued interest yearly , so this should not worry you. You report when interest is received. Same for your T-bills, etc. Moreover, the bond interest is not subject to Cdn taxation while you are non-resident of Canada. But, for calculation...
by nelsona
Tue Jan 21, 2020 9:39 am
Forum: Canada / United States Tax & Accounting
Topic: Canadian Student in USA
Replies: 3
Views: 311

Re: Canadian Student in USA

So you continue to file in Canada as a (deemed) resident, until you are considered resident of US, which is typically after 5 years on F1.

You probably should also be filing a 1040NR for the years you earned income in US as non-resident student.
by nelsona
Tue Jan 21, 2020 9:37 am
Forum: Canada / United States Tax & Accounting
Topic: Would Deferred Commissions Pass Permanent Establishment Test?
Replies: 10
Views: 618

Re: Would Deferred Commissions Pass Permanent Establishment Test?

it would be nice to bring all this information to the table in your first post rather that in drips and drabs. I guess you an go with the answer from the person to whom you gave most accurate information.
by nelsona
Mon Jan 20, 2020 7:15 pm
Forum: Canada / United States Tax & Accounting
Topic: Would Deferred Commissions Pass Permanent Establishment Test?
Replies: 10
Views: 618

Re: Would Deferred Commissions Pass Permanent Establishment Test?

Even US firms dealing with Cdns sometimes have to remit HST. Shouldn't be a problem.
by nelsona
Mon Jan 20, 2020 7:14 pm
Forum: Canada / United States Tax & Accounting
Topic: Canadian Student in USA
Replies: 3
Views: 311

Re: Canadian Student in USA

What was your Cdn filing status for the past five years?
by nelsona
Mon Jan 20, 2020 1:07 pm
Forum: Canada / United States Tax & Accounting
Topic: Would Deferred Commissions Pass Permanent Establishment Test?
Replies: 10
Views: 618

Re: Would Deferred Commissions Pass Permanent Establishment Test?

Then, indeed this would be self-employment income, not subject to tax in Canada, once you are non-resident.
by nelsona
Mon Jan 20, 2020 1:06 pm
Forum: Canada / United States Tax & Accounting
Topic: IRA management for Canadian residents
Replies: 11
Views: 938

Re: IRA management for Canadian residents

There are some private brokerage firms that have licenses in both countries, Pacifica and Blackmont come to mind. They woukd be able to accept the rollover.
by nelsona
Sat Jan 18, 2020 2:58 pm
Forum: Canada / United States Tax & Accounting
Topic: TN-Visa principal residence and pre-construction completion
Replies: 1
Views: 197

Re: TN-Visa principal residence and pre-construction completion

First, you are incorrect that you have one year to sell without US tax. You have one year to sell without CANADIAN tax. You have no US tax, if you have lived in the house two years, and then you get 3 years before US tax, 1, No, you will be liable in canada for the gains incurred while you were away...
by nelsona
Sat Jan 18, 2020 2:54 pm
Forum: Canada / United States Tax & Accounting
Topic: Would Deferred Commissions Pass Permanent Establishment Test?
Replies: 10
Views: 618

Re: Would Deferred Commissions Pass Permanent Establishment Test?

Permanent establishment would only apply to self-employment income. This sounds like employment income.
by nelsona
Sat Jan 18, 2020 2:52 pm
Forum: Canada / United States Tax & Accounting
Topic: Practically timing 401(k) to Roth conversion
Replies: 3
Views: 281

Re: Practically timing 401(k) to Roth conversion

Well, you should change your election at work so that you stop contributing to the Roth portion, as this indeed would be a Cdn contribution. You want to avoid that. I would be planning to stay in US for a month or so. Your Cdn residency date is simple: either when you cross the border (formally impo...
by nelsona
Fri Jan 17, 2020 3:39 pm
Forum: Canada / United States Tax & Accounting
Topic: Would Deferred Commissions Pass Permanent Establishment Test?
Replies: 10
Views: 618

Re: Would Deferred Commissions Pass Permanent Establishment Test?

This income would be taxable in canads (and US) in the years it is paid to you.
I don't know what permanent establishment has to do with your questions.
by nelsona
Fri Jan 17, 2020 3:36 pm
Forum: Canada / United States Tax & Accounting
Topic: Practically timing 401(k) to Roth conversion
Replies: 3
Views: 281

Re: Practically timing 401(k) to Roth conversion

You would need to accomplish this before becoming Cdn resident. The transfer takes days, so there is no real timing issue. Moving Roth funds between accounts does not create a Cdn contribution, and preserves the Roth. You will of course be paying US tax on the conversion. Any other questions related...
by nelsona
Fri Jan 17, 2020 3:32 pm
Forum: Canada / United States Tax & Accounting
Topic: treaty resident or citizen (pension 0% vs 15%)
Replies: 1
Views: 183

Re: treaty resident or citizen (pension 0% vs 15%)

The pension article in that treaty refers to "residents" on the contracting states, not citizens. So, the taxation of a US pension will be based on where the person lives according to US, Canada and Indian competent authorities.
by nelsona
Fri Jan 17, 2020 3:27 pm
Forum: Canada / United States Tax & Accounting
Topic: RRIF or IRA SEPP for supplemental income?
Replies: 5
Views: 305

Re: RRIF or IRA SEPP for supplemental income?

The reason RRSPs are not fully taxable is because they were not viewed as sheltered accounts. So, like if you brought a bag of money into IUS in 2006, why would you need to pay tax on that bag. You on;y pay tax on the income it subsequently generates. LIRAs on the other hand come from pensions, whic...
by nelsona
Fri Jan 17, 2020 3:25 pm
Forum: Canada / United States Tax & Accounting
Topic: RRIF or IRA SEPP for supplemental income?
Replies: 5
Views: 305

Re: RRIF or IRA SEPP for supplemental income?

The LIRA, and any portion of it that was put into your RRSP is 100% taxable. Any other RRSPs, are only taxable beyond what they were worth when you moved to US.