Serbinski Accounting Firms

I understand your frustration. Most of our cross-border clients get there FTCs reviewed on an annual basis and we have to constantly communicate with the department to show them our FTC calculations.

We've also had many long processing time waits for 1040s. That being said, after making the move to ...

Hi everyone

I thought this would be a great place to get some feedback. I've been doing some cross-border videos and would love to get some feedback.

Here are some examples:

https://youtu.be/knK1lidxAHE
https://youtu.be/KslX8ml-J3s

Here is the main channel: https://www.youtube.com/c/PhilHoganCPA ...

We're seeing lots of clients move back to Canada. Many had plans originally and now are finally making the move.

This resource may help:

https://philhogan.com/ira-401k-and-us-i ... dians-faq/

Hi Richard

This can get tricky. The answer will depend on several factors:

- Assuming the company is a CFC and had retained earnings in 2017, did you 1040 for 2017 include 965 calculations?
- As a CFC you'll also be subject to GILTI for 2018. Have you access these requirements yet? see here https ...

Hi Coco

This has become a huge issue for out clients. I've had over 10 clients with Fidelity be forced to close their accounts and in one case Fidelity forced a de-registration of a large IRA. Luckily we were able to reverse the transfer before the client cash the cheque they sent.

Fidelity is not ...

Are you a US citizen or only down temporarily?

Phil

At the very least you should be filing protective 1120-F returns and a treaty position (assuming you don't have a permanent establishment).

Please give me a call and we can chat about your options.

Cheers

Phil

That's the problem with extensions....give people a reason to put off filing.

Phil

Does your wife receive any US source income?

Phil

Not sure that I can complete the returns for (Canadian and US), but if they are relatively simple I should be able to get everything done for less than $2,000.

I'm in Victoria, and at the very least I could point you in the right direction.

Please give me a call and I'll see if I can help.

Cheers ...

ok then. So lets use an example:

US citizen living in Canada reports a $100,000 capital gain and pays (for argument sake) 15% plus 3.8% tax.

Before the 3.8% came in the taxpayer would pay $0 taxes because the gain was resourced.

Are you saying that they now will still pay $0 US taxes because the ...

Hi Nelsona

I should have been more clear. I'm really talking about Canadian residents with US citizenship that need to file both US and Canadian tax returns.

Phil

Has anyone considered the implication on the Canadian returns with respect to foreign tax credits available on the 3.8%?

Let assume taxpayer A earns 100% of their investment income from US sources. Will they be able to claim a foreign tax credit for the 3.8%. It's really an interesting questions ...

I have had some clients try, but from what I remember they had trouble making it work from Canada (may be different now).

Most clients however hate the idea of having to submit the forms through the "financial crimes enforcement network".

I don't blame them....

Phil

If you were considered a non-resident of Canada for the first 3 months the taxes withheld will be your final Canadian taxes.

The dividends and capital gains will be taxable on your US return and you'll be able to take a credit for the taxes withheld on the dividends via form 1116.

No Canadian tax ...