Serbinski Accounting Firms

sorry, poor typing.

Line should read "general rules suggest yes, the are NON-US source"

- US resident, receiving both RRIF distributions (15% withholding tax at source), CPP and OAS - US Federal average tax rate is less than 15%, so want to maximize the use of the Canadian withhodling tax on RRIF distributions Question: Are CPP and OAS income considered non-US source income for US tax ...

Scenario - A US citizen resident in Canada receives the 2008 Economic Stimulus payment in 2008. US Federal tax law says that the payments is not taxable in the US.

Would the receipt of this Stimulus payment be taxable in Canada?

I did a quick search, couldn't find anything discussed on this topic. The Department of Treasury released a new TDF form which applies to any TDF form filed after Jan 1, 2009. The form asks for more information (full address of non-US bank plus more exact highest balance in the account in the year. ...

The Department of Finance confirmed that the Treaty Protocols are now in force as of December 15 2008. Check the link that nelsona provided above for more info.

Where I think the real win could be for a US citizen is where they have a pool of excess passive basket foreign tax credits that may never get used. The US citizen will likely continue to add to this passive basket foreign tax credit pool where they have interest and dividends subject to Canadian ta...

Thanks for your input here nelsona. Your last sentence corresponds with my opinion on TFSAs for US citizens; generally not a good idea.

I can see the argument for "income" earned in a TFSA and how it could use excess foreign tax credits from other income outside a TFSA. By combining the two, there might not be any US Federal tax liability. Where I am concerned is how this would apply to capital gains as opposed to income. ...

For capital gains (other than US real property), wouldn't there be a risk that the gain could be sourced to the US? Under IRC Sec. 865(g)(2), personal property gains where the foreign tax paid is less than 10% are considered US source where a US citizen has a tax home outside the US. Since gains wit...