Serbinski Accounting Firms

Very helpful, thank you for the explanations and time!

All very useful, thank you Nelsona.

Just out of curiosity: it strikes me that most of what you have written here is about avoiding a situation where the tie break would need to be applied. Just to help my understanding, can you give an example of a circumstance in which the tie break would actually ...

Sorry, I should add, my appointment in the US requires me to be there regularly. My wife travels to our US home as often as I do.

I'm wading through all things, thank you Nelsona.

At present, I pass the SP test for both countries. I am attempting to apply tie break, not fail to pass SP for one of them. My novice reading is that the approach you advocate here would bypass the tie break issue entirely, since being a non ...

Sorry, I should have been clear: I am a US GC holder, and so am a US resident under IRS rules - my understanding is that, presence or not, PR are residents.

I am trying to determine where I tiebreak, I am hoping the wisdom of the crowd can help!

We maintain homes in both US and Canada, we rent in US and own in Canada. I'm not sure if this satisfies the 'permanent home' requirement of para 2 - but am presuming renters aren't left out in the cold, so ...

Thank you both - this has been great.

We have paid some salary to my wife, as much as we could justify given her involvement in the corp. It's not quite the optimal mix, but it's close to optimal, though optimized considering only Canadian tax rules.

My main worry was about double taxation - that ...

Thank you Nelsona.

"So in our case your CND dividend do not qualify for the long term cap gain tax rate of 5 to 15% but will be taxed as ordinary income. "

Does the tax paid on this and all "ordinary income" qualify for any kind of foreign credit? What I'm trying to surmise is, if we pay this out ...

We really very much appreciate the lengthy discussion, but I'm getting a bit lost. Some clarifications of the situation:

- my wife and I are now (as of Jan. 2011) residents of Canada, the corp was created only after we became so. I'm a little wary of declaring that fact to the IRS, since it may ...

Sorry, missed this detail - the corp was formed after we moved, the consulting wasn't allowed at my old job. We formed-up in June 2011, after moving at the end of December 2010.

I very much appreciate the quick reply.

I and my wife are both US persons (she is a citizen, I am a green card holder). At the beginning of 2011, we moved to Canada from the US. I have a day job, but do consulting work on the side, through a provincially incorporated corp, owned entirely by us (50/50). My wife did not have a job in 2011 ...