Serbinski Accounting Firms

Thanks, nelsona, for the quick reply.. I have _not_ been reporting the rent in Canada as expenses have exceeded income in all years (yes I was under the impression I didn't have to report because it was a loss). I am about to remedy this by amending the returns and claiming the losses. That is, if ...

I am a dual Canadian/US citizen and I reside in Canada. I file tax returns with both CRA and the IRS.

In 2003 I bought a rental property near New Orleans inside a single-member Louisiana LLC (created for the purpose of privacy, not taxes). The LLC is a disregarded entity in the eyes of the IRS. All ...

Say a US citizen who has resided in Canada most of her life dies. I understand her final 1040 is filed, and possibly a form 706 Estate Tax Return.

But what about after this? Income (dividends, interest, etc) in her Estate earned after death are reported on a T3 Trust Return in Canada. But what ...

[quote="nelsona"]That article only applies to LEAVING canada, since deemed acquisition on arrival in canada -- although it does satisfy the "treeted as having alienated a property" clause, does not satisfy "and is taxed in that State by reason thereof", since no tax arises from deemed acquisition ...

[quote="nelsona"]No you can't. [/quote]

I'm wondering if this is consistent with Article 13, paragraph 7 of the Tax Treaty:

7. Where at any time an individual is treated for the purposes of taxation by a Contracting State [Canada] as having alienated a property and is taxed in that State by reason ...

I am a dual Citizen (US/Canada) residing in Canada.
When I moved to Canada, the ACB of stocks for Canada was set by the deemed acquisition upon entering Canada. The ACB for the US remained unchanged.
The stocks are now held in Canada.
I assume the "Saving Clause" (Article 29, Paragraph 2) of the US ...