Search found 150 matches

by ND
Fri Jan 17, 2020 11:51 am
Forum: Canada / United States Tax & Accounting
Topic: treaty resident or citizen (pension 0% vs 15%)
Replies: 1
Views: 602

treaty resident or citizen (pension 0% vs 15%)

Can a taxpayer use 0% (Art XX pensions https://www.irs.gov/pub/irs-trty/india.pdf) of India-USA treaty for an Indian citizen who lives and works full time here in Canada under permanent resident status (immigration), versus 15% rate on periodic (XVIII CAN-USA treaty)? Since it’s an inheritance and w...
by ND
Tue Dec 24, 2019 9:47 pm
Forum: Canada / United States Tax & Accounting
Topic: US/CANADA Accountant recommendation?
Replies: 4
Views: 1331

Re: US/CANADA Accountant recommendation?

Why not google US tax accountants in Toronto or other major Cdn cities and see which non-advertised firms received the highest ratings?
by ND
Tue Jul 30, 2019 1:53 pm
Forum: Canada / United States Tax & Accounting
Topic: Form 8965 for Canadian
Replies: 6
Views: 1845

Re: Form 8965 for Canadian

The United States Department of Health and Human Services, the agency responsible for approving plans as MEC, has not approved Canadian universal health care. Where you live is irrelevant.
by ND
Fri Jul 12, 2019 12:10 pm
Forum: Canada / United States Tax & Accounting
Topic: Form 8938 and FBAR
Replies: 3
Views: 685

Re: Form 8938 and FBAR

FBAR includes any accounts you have access to
8938 threshold test includes your wife's assets but the actual 8938 reporting doesn't
by ND
Fri Jul 12, 2019 12:08 pm
Forum: Canada / United States Tax & Accounting
Topic: Dormant Consulting Company and Form 5471
Replies: 1
Views: 396

Re: Dormant Consulting Company and Form 5471

File just page 1 of 5471 and mark it dormant citing Rev Proc
by ND
Wed Feb 06, 2019 8:00 pm
Forum: Canada / United States Tax & Accounting
Topic: Dual Citizen living in US - Made interest on CDN bank account
Replies: 8
Views: 746

Re: Dual Citizen living in US - Made interest on CDN bank account

Don't forget to consider 8938 on your 1040 if you exceed the minimum threshold thru this and any other non-US specified assets. RE: If you know of a good accountant in the Bay area please let me know. Contact Wayne Baxter wbaxter@onecapital.com Executive Director 3075 Townsgate Road, Suite 350 Westl...
by ND
Wed Feb 06, 2019 7:18 pm
Forum: Canada / United States Tax & Accounting
Topic: 3520-A Penalty
Replies: 23
Views: 9563

Re: 3520-A Penalty

RE: And yes, they do think that TFSAs are trusts! I asked! Whoopdy do, the low level minimum wage processor, one of 100,000 IRS employees, told you you over the phone such and without citation. That employee probably doles out incorrect info on a regular basis. I personally spoke with the top intl t...
by ND
Wed Jan 02, 2019 10:25 am
Forum: Canada / United States Tax & Accounting
Topic: 3520-A Penalty
Replies: 23
Views: 9563

Re: 3520-A Penalty

RE: Hard to undo the fact that he has (a) already filed 3520 for previous years and (b) filed 3520-A late this year. The poster views it as a trust. Under that logic if a taxpayer mistakenly filed 3520 every year on account of owning a banana and thinking that requires 3520, the taxpayer cannot make...
by ND
Thu Dec 27, 2018 9:13 pm
Forum: Canada / United States Tax & Accounting
Topic: 3520-A Penalty
Replies: 23
Views: 9563

Re: 3520-A Penalty

note that a number of practitioners believe that TFSA is not a foreign trust and therefore not subject to 3520 filing at all. This argument provides one avenue of push-back. In fact, you can google and find template letters to IRS on web spelling out the reasoning and citations for such argument, a ...
by ND
Thu Dec 27, 2018 9:09 pm
Forum: Canada / United States Tax & Accounting
Topic: non resident filing jointly and FBAR
Replies: 4
Views: 672

Re: non resident filing jointly and FBAR

If outside the USA for 12 mos, can file obamacare exemption form (Code C) and be exempt from health care tax; if using tax software, once you input that info, it will zero out the tax.
by ND
Tue Jun 12, 2018 7:11 pm
Forum: Canada / United States Tax & Accounting
Topic: Taking stab at 3520, -A for TFSA
Replies: 157
Views: 133101

Re: Taking stab at 3520, -A for TFSA

Why not simply take the view of many practitioners that TFSA (or RESP) do not require 3520 reporting at all? No one has proven that they do nor has IRS opined or commented on the matter.
by ND
Mon Oct 09, 2017 1:50 pm
Forum: Canada / United States Tax & Accounting
Topic: matching RRSP deduction affected by yr of contribution, 8938
Replies: 5
Views: 1469

Reply - you got it right in saying "given it was a moving year, they may be some difficulty matching up the FTC" and his US source income aside from W2 includes NY condo rental income.
by ND
Mon Oct 09, 2017 11:02 am
Forum: Canada / United States Tax & Accounting
Topic: matching RRSP deduction affected by yr of contribution, 8938
Replies: 5
Views: 1469

Thanks for reply. RE "Only contributions made thru the employer DURING the tax year are eligible." Can you please cite the source for this? What blocks the argument from being made that the treaty allows on the US return the same matching RPP contribution as CRA allows on the T1 - and since CRA allo...
by ND
Sun Oct 08, 2017 11:03 am
Forum: Canada / United States Tax & Accounting
Topic: matching RRSP deduction affected by yr of contribution, 8938
Replies: 5
Views: 1469

matching RRSP deduction affected by yr of contribution, 8938

1. Can the XVIII(15) matching RRSP deduction be claimed for a non-commuter or ONLY for a commuter? 2. If said RRSP contribution was made entirely between Jan-March 2017 (claimed on the 2016 T1) can it be claimed on the 2016 1040 or must it only be claimed on the 2017 1040? 3. [unrelated to previous ...