Serbinski Accounting Firms

Would not the U.S company be required to withhold and remit 30% withholding taxes for contract payments to a non-resident ?

Never mind...I found it. Here we go again, ie soft disclosure vs. OVDI. Has ANYONE suffered with quiet disclosure when no tax liability was due ? Even when there is a tax liability has ANYONE been charged accuracy penalties or not been successful with reasonable cause with soft disclosure ? I hate t...

What 2012 OVDI are you referring to ?

I favor keeping this simple and doing it as a propreitrorship. The liability issues can be reduced via inusrance and\or indemnity clauses.

Has anybody noticed the "Important Information" that the Royal Bank has on there online login page ?

See: https://www1.royalbank.com/cgi-bin/rbac ... GE=ENGLISH

oooops...I met catagory 4

For a husband\wife Canadian corporation owned 50/50 where only one spouse is a USC, is this a catagory 5 for reporting on form 5471 ? Is it a Controlled Foreign Corp ?

Many thanks

I hope the holding company is not a controlled foreign corporation.

If a USC splits pension income with spouse on Canadian return then does the USC on U.S return claim entire income received ? This would result in insuffiecient ITC'S and U.S tax oweing...correct ?

Thanks for the clarification

Here is the downside:


"Individual U.S. shareholders are not entitled to use this foreign tax credit
mechanism unless they elect, in essence, to be taxed on subpart F inclusions at the combined U.S. corporate and individual effective tax rate of over 54%. "

Now I am confused again because I read this from "Controlled Foreign Corporation Tax Guide " Although U.S. shareholders of a CFC may be subject to current tax on the subpart F income of the CFC, losses are not passed through as deductions to the shareholders. This seems to contradict what ...

In a controlled foreign corp subpart f income is distributed to the U.S individual shareholder with no foreign tax credit available. However this election is apparently available as follows. HAS ANYBODY HAD EXPERIENCE WITH THIS ? IS THERE A DOWNSIDE ?

From "Controlled Foreign Corporation Tax Guide"

IRC Section 962 permits an individual shareholder of a CFC to be taxed (on the shareholder's proportionate share of the subpart F income of the CFC) as if the shareholder were a domestic corporation.

The primary benefit of this provision is that an individual shareholder will be
permitted to claim a foreign tax credit for foreign taxes paid by the foreign
corporations in which the taxpayer is a shareholder. Domestic corporations are permitted to claim a foreign tax credit for foreign taxes imposed on the subpart F income of CFCs in which the domestic corporation is a "U.S. shareholder.â€￾

Individuals who are "U.S. shareholders" of a CFC are not entitled to claim a
foreign tax credit for taxes paid by the foreign corporation unless they make this election under IRC Section 962.

Where an individual owns a 10% or greater interest in more than one CFC, the election applies to all of the CFCs in which the individual is a "U.S. shareholder" of a CFC.43

The election may only be made by an individual, an estate or a trust.

many thanks

Do you just simply reduce the subpart f CFC capital gains for the current year by the loss carried forward from prior years and put the net on line 1b of Worksheet A ?