Serbinski Accounting Firms

I did call the irs and got it all corrected. That's when they said the new balance was $0.

What I want to know is if this is the end of dealing with these returns or can they still be audited.

As a US citizen in Canada I filed 6 years of returns and fbars (2005-2010) in December 2011. Last week I received 2 bills from the IRS for taxes, penalties, and interest for 2009 and 2010. The returns I filed all had $0 owing. I looked at the reason they gave and it said for 2009 and 2010 I had give...

Thank you for the clarification. You appear to be correct on this matter.

What is the overall effect of completing the 5471 as a #2 instead of a #5? It seems that the #2 option requires significantly more to be disclosed regarding the financial statements of the business.

Thank you.

Ok, you may know more about this than I do, but this is what I was reading which seemed pretty clear:

Members of family
(A) In general
An individual shall be considered as owning the stock owned,
directly or indirectly, by or for -
(i) his spouse...

I think if you check closer you will find that you do constructively own all the shares, regardless of whether your wife is a USC or not. I don't have the precise location in the legislation here but if you check it is was pretty obvious that you are a 5.

Same issue for me. You are a 5 and it is a CFC due to attribution rules according to our CPA in Canada.

Contact the US consulate in your area and they have a questionaire you can complete which determines if you are a USC or not. If you don't want to contact them you can google 1405-0178 which is the form number and look at it yourself.

The capital gain was about $300k and I have not used any of my $750k lifetime CDN exemption. A butterfly or purification was done and was fully onside to provide the eligible CDN cap gain deduction but that does not apply for US tax, correct? So my understanding is the full $300k would be taxable at...

Sorry I should have said I was a US citizen living in Canada with no US income, property or ties since 1966. So does that mean Xiii(4) could be used to eliminate the 15% US tax on capital gains in Canada from the sale of a private Canadian company? Or does the savings clause effectively remove that ...

Does anyone have experience with Article 13 (paragraph 4) of the CDN/US tax treaty being used to eliminate US taxes on CDN capital gains from a small business sale?

One accountant said it could be used without any issue but it seems too good to be true.

Thank you.

Thank you for the reply. I have lived in Canada since 1966 and both a local CPA and the IRS confirmed I CAN file as HOH since my wife is a non-resident alien and I have 2 US citizen children in full time school and little income. But others have said I can't file HOH. Here is the line from the irs w...

Anyone have a comment on my question?

Has anyone had experience in filing a 1040 as Head of Household? I am dual and my wife is Canadian only. We have 2 dual citizen children. The reason I ask is 3 tax preparers have given us 2 different answers. Also, has anyone been hit with the AMT (Alternative Minimum Tax) while doing a 1040? My inc...