Serbinski Accounting Firms

Thanks JG,

However, the 500,000 exemption was used in a prior year. Where in the treaty does it say that if my Canadian Corporation is deemed to have a permanent establishment in the US, then it would not be subject to branch tax?

I am a Canadian resident that owns a Canadian Corporation. This Canadian Corporation is a 50% partner in a Limited Partnership in the US. Here's an example: At the end of the year, the LP shows 1 million of profit 500,000 is attributed to my Canadian Corporation This is all US Sourced Income From th...

My corporation is a limited partner in a US limited partnership. So at the end of the year, my corporation's part of the profits has tax owed to the US at the rate of 35%. That tax is recouperable on the Federal level in Canada with the foreign tax credit I receive from the US but I need to also rec...

Thanks for that, but look at the first line on TP-772-V

http://www.revenu.gouv.qc.ca/documents/ ... 05-10).pdf

Says the form cannot be completed by a corporation.

When looking at 20(12) deductions, it says that it's only for non-business. My problem is that I am paying US corporate tax of 35%. The US gives me a foreign tax credit note that I can apply to the Canadian Federal taxes, but there is nowhere to apply it to Provincial (Quebec) taxes. So my taxes end...

Hey Varus50, did you figure this out? I'm having the same problem but on a huge scale. I thought I would be able to use the foreign credit provincially but it seems you can't. Were you able to use T2203 the way you suggested?