Serbinski Accounting Firms

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 ...

Perhaps I wasn't clear: I didn't say there was no difference between resident and non-resident contributions, I meant to say there was no distinction between normal elected contributions, and forced contributions (ie catch-up contributions forced into a Roth401(k)).

I'm saying that if any Roth or ...

The folio was written with consideration of the treaty article that you quoted, and is well known.

As I said earlier, I don't see how there would be a distinction between different types of Roth401(k) contributions. Personally I would avoid making such contributions, as in my opinion it will make ...

Since the poster is a Cdn resident, the rollover to w Roth is not advisable. This would be considered Cdn contribution, effectively breaking the tax-freeness of the Roth fir CRA purposes.
Other than the fact that annuities are not viewed favorably by most advisors, in times of low interest rates ...

Whether or not you filed as US resident, you are allowed to participate in an HSA, if you have an HDHP. You won't be able to deduct your contributions on your Cdn return however.

What plan does your spouse have. If she is in an HDHP, you both can have an HSA, whether you have your own plan or not.

This year, Thanksgiving was on the latest possible November date, very close to December 1, so that may have caused some delays on the US bank side. Glad it showed up.

The treaty overrides any of these CRA regulations, so FICA is an acceptable foreign tax.

Article II(2)(b)(iii)

I doubt that it meets the requirements of either FBAR or 8938.
HOWEVER, she is becomeing a beneficiary of a foreign trust, which introduces 3520 issues, and at the very least It is also a gift, reportable on 3520, assuming her parents are non-YS citizens.

Why are the parents going through this ...

... your own home.

Assuming you left Canada in a previous year, and are thus a non-resident, you would file a non-resident return, reporting no income (income subject to NR tax, like dividends and interest are not reportable on a non-resident return, and include SCH 7. Nothing to do with treaty.

Be sure that your Cdn ...