Search found 754 matches

by JGCA
Fri Apr 16, 2021 10:11 pm
Forum: Canada / United States Tax & Accounting
Topic: Selling property in Cdn buying in US
Replies: 2
Views: 1504

Re: Selling property in Cdn buying in US

Please note Nelsona said you have no final tax in Canada however the attorney in Ontario will withold 25% of the Gross Selling price in escrow for CRA until you submit a reduction certificate for tax request with CRA this has to be done at the time of selling or else the attorney will have to hold 2...
by JGCA
Fri Apr 16, 2021 9:54 pm
Forum: Canada / United States Tax & Accounting
Topic: Canadian subsidiary
Replies: 3
Views: 1821

Re: Canadian subsidiary

You say its a Canadian Subsidiary owned by a Delaware US C Corp meaning you will not be considered as a CCPC ( Cnd Controlled Private Corp) unless you are not controlled meaning less than 50 % ownership by a US corp both de facto and other types of factors o see if you can control the sub or not By ...
by JGCA
Sun Feb 10, 2019 2:44 pm
Forum: Canada / United States Tax & Accounting
Topic: New 2018 Changes Posted By Marl
Replies: 0
Views: 5724

New 2018 Changes Posted By Marl

I have read through the 2018 Changes posted by Mark Serbinski on his 2018 Tax Changes Board and would like to add the following comment for something I feel most readers in this forum would care to know. The Passthrough Deduction for Qualified Business Income the definition that excludes Specified S...
by JGCA
Fri Aug 24, 2018 12:33 pm
Forum: Canada / United States Tax & Accounting
Topic: Determining Whether Dividends from Cdn Companies Qualified for IRS Purposes
Replies: 4
Views: 2641

Re: Determining Whether Dividends from Cdn Companies Qualified for IRS Purposes

No CND taxpayers only get T5 or T3 and it would not appear, I was under the assumption the question was for a non resident if not then no NR4 is issued but if the taxpayer is located in the US they would get a NR4 and it would specify it
by JGCA
Thu Aug 23, 2018 4:21 pm
Forum: Canada / United States Tax & Accounting
Topic: Determining Whether Dividends from Cdn Companies Qualified for IRS Purposes
Replies: 4
Views: 2641

Re: Determining Whether Dividends from Cdn Companies Qualified for IRS Purposes

yes dividend from large cap public companies would be treated as qualifying for US tax purposes and would be so indicated on the NR4 slips given to you at year end
by JGCA
Thu Aug 23, 2018 4:16 pm
Forum: Canada / United States Tax & Accounting
Topic: Catching up on Tax Compliance
Replies: 8
Views: 4755

Re: Catching up on Tax Compliance

you should consider having an accountant or cross border expert do this or at least give you guidance. Your problem is not the modest tax you may or may not owe but the failed FBAR and other disclosures you have not done this has nothing to do with tax owed its the penalties for non compliance and a...
by JGCA
Thu Aug 23, 2018 4:10 pm
Forum: Canada / United States Tax & Accounting
Topic: NR95
Replies: 2
Views: 2179

Re: NR95

This NR95 from is to allow other individuals to obtain information on your behalf from CRA non resident tax and trust accounts NOT fro the General T1 returns such as the Sec 216 return this is not governed by this authorization the standard from is for this. Basically your agent may have requested C...
by JGCA
Thu Aug 23, 2018 4:00 pm
Forum: Canada / United States Tax & Accounting
Topic: Dual Citizen living in Canada, contracting for US firm
Replies: 4
Views: 5749

Re: Dual Citizen living in Canada, contracting for US firm

As for the GST TVQ side as long as your worldwide sales in the calendar year do not exceed $ 30K CND you do not need to worry about the GST TVQ which would be zero rated since the sales are originating from outside Canada. This of course assumes you will be reporting the income on your T1 and QC TP1...
by JGCA
Sun Nov 05, 2017 10:39 am
Forum: Canada / United States Tax & Accounting
Topic: T1135 - VDP Process
Replies: 6
Views: 4467

ok do it now before they change the rules
by JGCA
Sat Nov 04, 2017 3:37 pm
Forum: Canada / United States Tax & Accounting
Topic: T1135 - VDP Process
Replies: 6
Views: 4467

CRA require 10 years if T1135 min penalty is $ 2500 a year for just not filing, better hurray they are changing the rule for VD was suppose to be Jan 1 18 but it just got announced that the old rules will apply till Sept 2018. You need a person who has done this befor do best way to do it is to file...
by JGCA
Mon Oct 23, 2017 8:30 pm
Forum: Canada / United States Tax & Accounting
Topic: Moving to Canada - huge potential obstacle Help!
Replies: 21
Views: 9601

Changing it back to a C corp would help you a lot in the tax treatment especially claiming foreign tax credits since you would be getting a salary and the salary would be taxes as such on both sides allowing you to claim FTC. However as Nelson explained you will still need to set up a payroll in Can...
by JGCA
Sun Oct 22, 2017 11:05 am
Forum: Canada / United States Tax & Accounting
Topic: Moving to Canada - huge potential obstacle Help!
Replies: 21
Views: 9601

First thing I see is that you have an S Corp and for US tax purposes its NET income is simply added to your 1040 at year end so in essence its treated as as registered business for US purposes not in any way as a corporation. I Canada CRA will not allow you to simply enter this as business income it...
by JGCA
Fri Dec 30, 2016 3:22 pm
Forum: Canada / United States Tax & Accounting
Topic: Canadian Corporation Fiscal Year questions
Replies: 2
Views: 2071

You are using a CND corp to produce income from your business activities in the US so first of all is the Corp resident in the US. In 2016 it looks as if you were not in the US more than 183 days unless you have a permanent office in the US you could still claim its a non resident for tax filing in ...
by JGCA
Sun Dec 04, 2016 5:17 pm
Forum: Canada / United States Tax & Accounting
Topic: W-8BEN-E and Canada-US Tax Treaty
Replies: 10
Views: 5296

What you need to do is simply file a treaty based corp tax from 1120F in the US to say under the treaty you will be paying all tax in your home based country Canada I=under the relevant tax treaty Articles you mentioned you still have to file a treaty based corp tax return othereise IRS can assess y...