Search found 29 matches
- Fri Nov 11, 2011 12:06 pm
- Forum: Canada / United States Tax & Accounting
- Topic: Mother is Emigrating from Canada to USA ....
- Replies: 21
- Views: 10350
'You're are implying that there is an IRS requirement for US Canadian non-residents to report undistributed income earned in an Canadian company ' He's not implying it, he's saying it and he's 100% correct. A Controlled Foreign Corporation has very special rules under US tax laws about disbursing in...
- Thu Oct 13, 2011 6:29 am
- Forum: Canada / United States Tax & Accounting
- Topic: Dual Citizen /US CItizen Living Almost Entire life in Canada
- Replies: 2
- Views: 2568
- Mon Sep 26, 2011 4:38 pm
- Forum: Canada / United States Tax & Accounting
- Topic: the highest aggregate balance of the year
- Replies: 171
- Views: 100713
- Thu Sep 15, 2011 3:34 pm
- Forum: Canada / United States Tax & Accounting
- Topic: Backfiling 8621 ?
- Replies: 8
- Views: 5540
- Thu Sep 15, 2011 3:10 pm
- Forum: Canada / United States Tax & Accounting
- Topic: Backfiling 8621 ?
- Replies: 8
- Views: 5540
If there are distributions or sales, then you are required to file form 8621. You cannot mark to market unless you first bought the PFIC within the period in question (i.e if you bought a particular PFIC 10 years back and you're backfiling 4 years of returns you cannot do MTM). You CAN do MTM if you...
- Thu Sep 15, 2011 2:44 pm
- Forum: Canada / United States Tax & Accounting
- Topic: Backfiling 8621 ?
- Replies: 8
- Views: 5540
- Mon Sep 12, 2011 7:39 am
- Forum: Canada / United States Tax & Accounting
- Topic: FBAR and 8891 backfiling
- Replies: 5
- Views: 4332
- Mon Sep 12, 2011 7:24 am
- Forum: Canada / United States Tax & Accounting
- Topic: Canadian NON RESIDENT moving to US
- Replies: 12
- Views: 6618
- Thu Sep 08, 2011 10:49 am
- Forum: Canada / United States Tax & Accounting
- Topic: Was OVDI the right choice for honest Cdn resident?
- Replies: 12
- Views: 9572
I am in violent agreement with that. All I was saying was that all QDs likely go to a CI person first, who does a quick check to verify that they are not investigating this case or have some other reason to be interested (say, really large sums of tax due, accounts in multiple tax havens etc.). And ...
- Thu Sep 08, 2011 6:14 am
- Forum: Canada / United States Tax & Accounting
- Topic: Was OVDI the right choice for honest Cdn resident?
- Replies: 12
- Views: 9572
I didn't say that QD triggered a criminal investigation (any more than VD does). What I said was that QDs (at least those involving foreign accounts) are likely sent to a CI agent for vetting in any case (just as VDs are). Since the original poster seemed to be concerned about being branded a crimin...
- Wed Sep 07, 2011 6:00 pm
- Forum: Canada / United States Tax & Accounting
- Topic: Was OVDI the right choice for honest Cdn resident?
- Replies: 12
- Views: 9572
You don't sound like a good candidate for OVDI. And $15K for your paperwork seems extortionate. You would probably qualify for the 5% penalty, but even that might be too much for you. I don't think you would need professional help with your paperwork (and certainly not 15K worth). If it makes you fe...
- Tue Sep 06, 2011 9:12 am
- Forum: Canada / United States Tax & Accounting
- Topic: FBAR penalties and soft disclosure
- Replies: 16
- Views: 14936
The IRS internal replies from the regular FBAR email address are sometimes unclear or contradict the FAQ or even each other at times (or maybe the person did not understand the question clearly). But, the IRS has said in its OVDI FAQ that its not just tax due that is an issue, its also unreported in...
- Tue Sep 06, 2011 6:44 am
- Forum: Canada / United States Tax & Accounting
- Topic: How to calculate interest on taxes on for OVDI penalty
- Replies: 10
- Views: 6831
Technically, the accuracy penalty needs to be compounded separately if you filed an extended return any year, since the accuracy penalty is only from the extended due date, whereas tax due is compounded from the due date. Also, the %age changes quarterly, not yearly. Plus, its compounded daily, and ...
- Mon Sep 05, 2011 7:27 pm
- Forum: Canada / United States Tax & Accounting
- Topic: Free Tax Filing Software for U.S. Income Taxes?
- Replies: 4
- Views: 3624
- Mon Sep 05, 2011 7:21 pm
- Forum: Canada / United States Tax & Accounting
- Topic: OVDI FAQ #17
- Replies: 16
- Views: 13806
If your lawyer is relying on the 'laziness' of IRS agents, then it seems to me that it would be better to do quiet disclosure, since there is at least some sort of discretion, where as once submitted to OVDI, there is no discretion and a formalized process to track entries. My understanding is that ...