Serbinski Accounting Firms

So as I understand it and to be clear...a subpart f loss is deemed a capital loss and can be used to offset future CFC gains ? Where do you put the prior year capital loss to offset current subpart f income on the 5471 ?

For a controlled foreign corporation, am I correct that an investment loss that otherwise would be considered subpart f income if it were income cannot be deducted ? In otherwords, you cannot deduct subpart f losses ?

In summary, as I understand it, if you are backfiling then the election for mark to market is not timely and you must treat distributions from a pfic as a Section 1291 fund... So if you received a distibution in 2006 then you determine the excess amount, prorate it back to beginning of fund, apply h...

Madhoa, I'm glad I am not the only one confused....

Bottom line..if there are distibutions in past years do I have to file 8621 and can I mark to market ? If I do not have to file 8621 then I presume I report distributions as I do for Cdn taxes.

Is there a definitive answer ?

Thanks

Ok...I think I found an answer to part of my question, ie "On April 6, 2010, the IRS published Notice 2010-34 which provided that PFIC shareholders not otherwise required to file Form 8621 annually before Sec. 1298(f)’s enactment would not be required to file an annual report under Sec. 1298(...

Can you backfile a mark-to-market election using form 8621 or are you stuck treating it as a Section 1291 fund...or something else? In plain talk..what do you do when you have not filed and plan to go back six years and have unregistered mutual funds for all those years ? Thanks..and I apologize if ...

I would appreciate any comments on whether anybody has had trouble filing form 8891 elections late. SEE http://www.moodystax.com/blog/33-us-taxation-services/159-act-now-to-fix-the-us-income-tax-problem-with-your-rrsp-that-you-probably-didnt-know-you-had.htmlhttp:/www.moodystax.com/blog/33-us-taxati...

You mention that you had your copes "notorized". Notorized copies by Cdn lawyrs or notoary publics are not acceptable to the IRS. They have to be certified by a IRS Certifying Acceptance Agent.

You confimed what I thought...thanks

coorection to my original post...all cpp and oas is exempt to US so ignore the 15% comment.

If I claim Treaty XVIII.5 for CPP and OAS on Form 8833 can I still claim all my foreigh tax credits ? If not, do I have to subtract out the full amount related to total income form OAS and CPP or just the amount related to the 15% taxable ?

Thanks

Thanks Nelsona.....I get it now !

I have spent hours reviewing your posts and can't seem to get a grip on this. He is a US citizen living in Canada for entire life. He has not filed and will be filing the past six years. Nelsona I really appreciate you contributions and I hate to ask you to repeat things....if you can just provide s...

What is the taxable income on a RRIF withdrawal if the RRIF earns more that the withdrawan amount ? Is it the total earnings for the year ? The total amount withdrawn ? Or some other amount. I have searched all over forum and I don't get it. PLEASE HELP !

thanks

Can ANYONE provide me a link to this CRA announcement or some kind of verification. I have searched all over and just see references but no first hand statement from CRA.