Search found 25 matches
- Fri May 04, 2012 5:05 pm
- Forum: Canada / United States Tax & Accounting
- Topic: Canadian Deemed Dividend a Qualified US Dividend?
- Replies: 12
- Views: 14312
Canadian Deemed Dividend a Qualified US Dividend?
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 report...
- Thu Dec 08, 2011 11:58 am
- Forum: Canada / United States Tax & Accounting
- Topic: Defered Departure Tax ... does it have to be paid?
- Replies: 19
- Views: 11240
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 che...
- Wed Dec 07, 2011 5:04 pm
- Forum: Canada / United States Tax & Accounting
- Topic: Defered Departure Tax ... does it have to be paid?
- Replies: 19
- Views: 11240
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 not...
- Wed Dec 07, 2011 4:02 pm
- Forum: Canada / United States Tax & Accounting
- Topic: Defered Departure Tax ... does it have to be paid?
- Replies: 19
- Views: 11240
- Wed Dec 07, 2011 11:21 am
- Forum: Canada / United States Tax & Accounting
- Topic: Defered Departure Tax ... does it have to be paid?
- Replies: 19
- Views: 11240
Defered Departure Tax ... does it have to be paid?
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 compan...
- Fri Nov 11, 2011 11:48 am
- Forum: Canada / United States Tax & Accounting
- Topic: Mother is Emigrating from Canada to USA ....
- Replies: 21
- Views: 13411
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 Can...
- Fri Nov 11, 2011 11:27 am
- Forum: Canada / United States Tax & Accounting
- Topic: Mother is Emigrating from Canada to USA ....
- Replies: 21
- Views: 13411
- Fri Nov 11, 2011 10:08 am
- Forum: Canada / United States Tax & Accounting
- Topic: Mother is Emigrating from Canada to USA ....
- Replies: 21
- Views: 13411
- Thu Nov 10, 2011 5:51 pm
- Forum: Canada / United States Tax & Accounting
- Topic: Property Deemed Disposed of on departure by Canadian to USA
- Replies: 20
- Views: 13098
- Thu Nov 10, 2011 4:30 pm
- Forum: Canada / United States Tax & Accounting
- Topic: Property Deemed Disposed of on departure by Canadian to USA
- Replies: 20
- Views: 13098
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 dividends...
- Thu Nov 10, 2011 2:57 pm
- Forum: Canada / United States Tax & Accounting
- Topic: Property Deemed Disposed of on departure by Canadian to USA
- Replies: 20
- Views: 13098
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 20...
- Thu Nov 10, 2011 2:22 pm
- Forum: Canada / United States Tax & Accounting
- Topic: Property Deemed Disposed of on departure by Canadian to USA
- Replies: 20
- Views: 13098
- Thu Nov 10, 2011 2:18 pm
- Forum: Canada / United States Tax & Accounting
- Topic: Property Deemed Disposed of on departure by Canadian to USA
- Replies: 20
- Views: 13098
- Thu Nov 10, 2011 12:10 pm
- Forum: Canada / United States Tax & Accounting
- Topic: Mother is Emigrating from Canada to USA ....
- Replies: 21
- Views: 13411
- Thu Nov 10, 2011 11:59 am
- Forum: Canada / United States Tax & Accounting
- Topic: Property Deemed Disposed of on departure by Canadian to USA
- Replies: 20
- Views: 13098
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 marketa...