Serbinski Accounting Firms

Would the CRA assist the IRS in collecting a CIVIL penalty ? I doubt it. Maybe I am mistaken, but assuming the worse case and a penalty is assessed....how can they collect ?

Do I understand this correctly...If a Canadian Corporation does business in the U.S and as long as the Canadian corporation does not have any permanent establishment in the U.S or corporate personnel have spent less that 183 in the U.S providing services then the earnings from the U.S are exempt via...

Thank-you NickH for your comments. I was not aware that some Cdn mutual funds were issuing statements if requested. The problem I see with mark-to market is double taxation since the funds will be taxed in the U.S with no offsetting foreign tax credits then taxed again in another period in Canada wh...

Thank-you NickH and Patti for your comments. It is my understanding to make the QEF election the fund must provide you information in approved IRS form and no Canadian mutual fund has qualified to do that because they must also adhere to SEC regulations which is added cost to them. Therefore this el...

No opinions? Surely others are dealing with this issue. Please email me your comments if you don't want a public post. I am very interested in other options and opinions.

Thanks

It seems to me that a USC holding Canadian mutual funds has a real dilemma. Assuming said mutual funds are passive foreign investment corporations and do not qualify as a Qualifying Electing Fund the options are: 1) opt for mark to market election which generates tax in US. The foreign tax credits c...

Extending this a bit further...If you are a U.S citizen residing in Canada, under age 65 and receiving social security disability benefit as your only income.....is it still necessary to file a U.S tax return ?

If a dual citizen residing in Canada transfers real Canadian property that was jointly owned to her Cdn spouse, is the transfer considered a deemed disposition for U.S tax purposes as it is in Canada ?

You have asked a great question and I hope we get some replies.

When you sell the farm property it will most likely be exempt from capital gains tax in Canada but not in the US.

thanks jg

So to be clear, a U.S LCC for a Canadian resident US citizen: 1) flows income to the taxpayor via US 1040 2) reports income on Cdn non-resident T2 Corporate return ? 3) reports income to Canada as dividends with no dividend tax credit since they are foreign dividends ? How are the foreign tax credit...

I'm confused...how is rental property income double taxed in Canada ? I understand the LCC is considered a foreign corp in Canada an the income is considered foreign dividends by the Canadian taxpayor. How is it double taxed ? Thanks

You can get a CRA opinion by completing the following form and sending it into CRA: http://www.cra-arc.gc.ca/E/pbg/tf/nr73/nr73-11e.pdf

ignore my post...