Serbinski Accounting Firms

1. I sold all my company assets and held only cash in the company.
2. I have moved to the USA and now own the company as a non-resident. All filings were reported.
3. I realize I will never move back to Canada, and I have decided to cash in.l
4. The Canadian accountant said no problem, I will ...

General comment. I read a lot of information on many sites (IRS and CRA included) and this is the most informative site I have ever been too. I double check all information, and any all information posted here has been cooberated eslsewhere, Furthermore, what others claim to be true, when double ...

As to whether or not wind-up is a dispostion, I would be relying on IT-126R2 rather than anything that has been said here. .... the issue as I see it is not whether or not a wind-up is a dispostion, but whether or not a wind-up is a sale of shares that triggers payment of departure tax.


byw, I'm ...

I would think you would have needed to do this before leaving Canada. .."the T1244 states definitively you do not have to pay until asset disposed of. I have called CRA to confirm deferral.

To be clear, you do not need to pay the departure tax, so long as there are assets against it (collateral if ...

I filed election T1244 for deferred departure tax on shares owned in a CCPC. According to regulations, departure tax becomes payable when asset is actually sold.

Now Nelsona on another thread informed me that a wind-up of a corporation is not a sale, based on this information, if I wind-up my ...

You still haven't shown why there is an issue with past IRS filings concerning my mother. You're are implying that there is an IRS requirement for US Canadian non-residents to report undistributed income earned in an Canadian company ....

Is the question reporting income or disclosing income. In ...

"EXACTLY!!! Find someone who does. How often do you need to be told. You screwed yourself, now don't screw up mum's nest egg too."

1. I haven't paid the departure tax it's only differed, so I am not out of pocket.
2. I haven't wound up my company, so there is no deemed dividend to pay. I don't need ...

"all income was earned in Canada and IRS filing was done based on personal income tax prepared"


Nelsona writes: "See. You need help already."

Blairgoates writes: "I hope the holding company is not a controlled foreign corporation."

I do not see what the issue is. Mom (born in the USA) as ...

Nelsona: to clarify. "Now you say you were told it could." ... this advice was given to me by cnd. advisor and I accept that you and JCGA are correct when you state " both JCGA and I have brought up, you took a dividend, not proceeds from sale."

So I accept that what you are stating is correct and ...

I do not know how things got so confused. The issue is this:

1. On Aug 2009 I left Canada for a university job in the USA.
2. In Canada I did consulting revenue and invested in marketable securities via a CCPC that allowed low rate of tax on business income (and refundable taxes on taxable ...

OK I think I have big picture ..

Nelsona wrote : So you had deemed disposition in 2009 tax on 219,000 ... and no tax in US (you get a 44K cap loss to use). ... o clarify: departure tax is based on FMV on date of departure. Deemed disposition is actual disposition at date of wind-up anticipated in ...

nelsona wrote: "So where is the foreign tax you need to pay?" since I am resident in USA, isn't the deemed dividend on wind-up taxable in the USA?

nelsona wrote: "So you had deemed disposition in 2009 tax on 219,000 ... and no tax in US (you get a 44K cap loss to use)"

JGCA wrote: "On a wind up you did not have a deemed disposition you had a deemed dividend and the resulting capital loss on the retration of the shares is not considered as a ...

nelsona wrote:

"Corporate compliance, estate tax, departure tax, gift tax, foreign corporation, RRSP and foreign trust reporting." .. thx. I agree.

"She either already has a pro (these all have issues even if she doesn't live in US), or absolutely needs one before setting foot in US, not internet ...

nelsona wrote:

What price did you deem dispose of these shares in canada, ... $216,000 in Canada in 2009

and what price did you actulaly dispose of them in US? --- while US resident proposed November 30, 2011 shares to be disposed via wind up at 175,000 (decrease due to reduction in value of ...