Serbinski Accounting Firms

If a US citizen living in Canada sells a US stock at a loss and immediately buys it back in his IRA, I understand that both countries disallow the loss. But what happens if the bulk of the loss was long-term (>1 year) but the portion that was short-term was actually a gain? It appears that despite a...

"You do each return with no accounting for foreign tax credits. Then you complete your Cdn one accounting for any allowed US tax from the preliminary US return. Then you do you complete your US one, using the the completed Cdn return. No other iterations." At which stage do you use the 255...

So you don't think the IRS would come after an individual USC that holds a Canadian ETF even if it does seem to "technically" meet the test of being a PFIC? (Actually, I guess the issue only comes to a head when a USC *sells* a PFIC at a gain. I can't find any evidence that there are any p...

Hi Nelsona, After re-reading this thread, I am very concerned about the notion that Canadian Funds/ETFs may be considered PFICs. I have done numerous searches on the internet and reviewed the few published opinions that I could find (including those quoted above by eortlund), and it seems that you a...

"Well, one thing to remember is your friends really had no option as to what to do. Roth was not an option for them. And SEPP is not really helping them, as their marginal is still higher. Witha Roth, one need not worry about SEPP." Hmmm.... Well, yes it's true that the Roth was not an opt...

Nelsona - You're making the conventional assumption that the typical retiree leaves work around the typical 65 years and withdraws an amount similar to what they were making while working. I am aware of a couple people that made really healthy wages while working (>$100k) but retired in their 50's w...

Does the CRA only require a copy of the signed 1040 (i.e. 2 pages) in order to get FTCs for US tax paid? Or do they also want to see the full US return with all the attachments (e.g. schedules, forms, etc)?

Sounds to me like these are some gray areas where the authors are taking pretty aggressive interpretations. As for Canadian mutual funds and ETFs being considered PFICs, that sounds like a very aggressive interpretation doesn't it? All such funds distribute all their income on an annual basis and it...

Nelsona - As always, thank you so much for your insights and expertise!!!

Nelsona - Thank you so much for your response! Hmmm, what you have described does certainly sound painful! Without doing 20-30 different form 1116's (for every country), a USC would end up paying 8% tax to the 3rd party governments (withheld by ETF), 10% to the US government (effective tax rate), an...

Having re-read many of the old posts on how a US citizen handles dividends while residing in Canada, there is still one thing that I still don't understand. What happens when the dividends are paid by a US-domiciled ETF (e.g. Vanguard, iShares, etc) that invests in international stocks (e.g. Europea...

Just for giggles, I'll give you another example. If a USC is an early retiree living in Canada and has a substantial portion of their income coming from Canadian dividends. For example, if you make $30k of income of which $15k is from interest and $15k is from Canadian dividends, you will owe more t...

Yes, I read "Otto's thread" and that's where I got the idea that tax would be owed to the IRS on US-sourced dividends. In your post on March 30, 2009 @ 15:17 you gave "cfn2007" an example where he would have to pay ~$102 to the IRS as a result of having US-sourced dividends. How ...

"The goal should be to pay no tax on your US return, as Cdn tax is usually a little higher that US rate. " Wouldn't that be difficult given that he has US stock & MF dividends? As US-sourced income, any US tax on this portion of income would need to be recovered with FTCs on his Canadi...

New guidance just issued by the IRS for expatriates/renunciants:

http://www.irs.gov/irb/2009-45_IRB/ar10.html