Search found 3 matches

by waldo
Tue Jan 03, 2012 7:01 pm
Forum: Canada / United States Tax & Accounting
Topic: TFSA and 3520
Replies: 11
Views: 6948

All the points you raise are good ones. But in the absence of any clear statement from the IRS, I think my takeaway is that Americans living in Canada should avoid TFSAs like the plague until an 8891-like clarification is made available. The donation space accrues over the years, so if someone sets ...
by waldo
Tue Jan 03, 2012 5:17 pm
Forum: Canada / United States Tax & Accounting
Topic: TFSA and 3520
Replies: 11
Views: 6948

But a bank is not a person. The definition clearly states that the assets are help by a person for another person. Do the CRA and the IRS even have the same definition of what a trust is? While the TFSA may be a "trust" by the CRA's definition, that doesn't mean it meets the IRS definition...
by waldo
Tue Jan 03, 2012 5:01 pm
Forum: Canada / United States Tax & Accounting
Topic: TFSA and 3520
Replies: 11
Views: 6948

Does anyone have a reference in which the IRS specifically states that TFSAs are to be treated as trusts (i.e. a 3520 must be filed)? I can't find it, but I did find this IRS definition of a trust: http://www.irs.gov/charities/article/0,,id=96116,00.html "In general, a trust is a relationship i...