Serbinski Accounting Firms

A US engineering consultant will be coming to Canada every month or so to meet with existing and prospective clients. He will be in Canada just a few days at a time, and most of the work will be done in the US. The US-Canada treaty says a US resident has a permanent establishment in Canada if the ...

In general, under Canadian tax law, assets held in trust are deemed sold every 21 years. Suppose the trust distributes all of its assets in year 20. Is the distribution from the trust to the beneficiaries a deemed disposition under Canadian tax law? Seems like it must be; otherwise, there would be a ...

Suppose a US citizen owns a RRIF and defers US tax by filing Form 8891. At death, the RRIF passes to a Canadian spouse who has no US status. Does spouse pay US tax on income deferred through the Form 8891? It seems like the income should be recaptured for US purposes, but the mechanics of how the ...

I have the same exact question, and have carefully researched it without resolution. It seems like the income deferred by reason of the Form 8891 election should be US source income, but I don't see how the IRS can collect the tax. Please let me know if you are able to secure any guidance on this.