Search found 17 matches
- Wed Jun 03, 2020 2:45 pm
- Forum: Canada / United States Tax & Accounting
- Topic: Inherited Roth IRA
- Replies: 2
- Views: 1174
Inherited Roth IRA
Hi, we know all about the one-time CRA election that lets a new Canadian immigrant Roth IRA holder prevent future taxation on the Roth under Treaty XVIII 3(b) and (7). My question is, in the case of a Canadian resident dual citizen inheriting a Roth IRA from his deceased US resident mother, we know ...
- Wed Jan 29, 2020 5:52 pm
- Forum: Canada / United States Tax & Accounting
- Topic: Non-resident doctor working in Canada - PE or not?
- Replies: 1
- Views: 1250
Non-resident doctor working in Canada - PE or not?
Take the case of a medical doctor who moved to the US and formally departed Canada for tax purposes in 2019, but who will continue to perform his medical services exclusively in a remote location in northern Canada by commuting back and forth. The question is whether he'll remain taxable in Canada a...
- Wed Nov 07, 2018 3:49 pm
- Forum: Canada / United States Tax & Accounting
- Topic: reversing Treaty election XIII(7)
- Replies: 1
- Views: 1045
reversing Treaty election XIII(7)
If a Canadian who moved to the US already filed their US tax return for the year of the move with the treaty election under XIII(7) to bump up ACB to FMV on all assets subject to departure tax, do you have any idea if the US return can be amended after the fact and the bump-up election reversed?
- Fri Jul 28, 2017 3:29 pm
- Forum: Canada / United States Tax & Accounting
- Topic: RRIF conversion timing
- Replies: 3
- Views: 2436
- Fri Jul 28, 2017 11:46 am
- Forum: Canada / United States Tax & Accounting
- Topic: RRIF conversion timing
- Replies: 3
- Views: 2436
RRIF conversion timing
Eddy Eager and Larry Lazy are both RRSP holders of the same age (under 71) who move to the US in fall 2017. Eddy converts his RRSP to a RRIF before year-end 2017, while Larry converts his in early 2018. Since the ITCIA periodic payment definition relies on a start of year RRIF value, does Eddy techn...
- Tue Aug 16, 2016 9:52 pm
- Forum: Canada / United States Tax & Accounting
- Topic: When to notify CRA of exit
- Replies: 5
- Views: 3418
- Tue Aug 16, 2016 6:55 pm
- Forum: Canada / United States Tax & Accounting
- Topic: When to notify CRA of exit
- Replies: 5
- Views: 3418
When to notify CRA of exit
The common wisdom is NOT to notify CRA of Cdn departure except by way of indicating the departure date on the exit return due the following April. Similarly, the common advice about notifying all payors about the address change so as to sever ties and ensure proper withholding extends to Service Can...
- Fri Aug 12, 2016 11:03 am
- Forum: Canada / United States Tax & Accounting
- Topic: US withholding on lump-sum pension payment - periodic?
- Replies: 3
- Views: 2652
- Wed Aug 10, 2016 2:17 pm
- Forum: Canada / United States Tax & Accounting
- Topic: US withholding on lump-sum pension payment - periodic?
- Replies: 3
- Views: 2652
US withholding on lump-sum pension payment - periodic?
Re NRA withholding on FDAP income, IRS rule 1.1441-2(b)(ii) says that it is immaterial whether the payment is made in a series of payments or in a single lump sum. According to this logic, for US source pension withdrawals made by NRAs, both lump sum AND periodic withdrawals should fall under Treaty...
- Tue Jul 19, 2016 2:25 pm
- Forum: Canada / United States Tax & Accounting
- Topic: W-8BEN quick questions
- Replies: 3
- Views: 1979
- Tue Jul 19, 2016 1:07 pm
- Forum: Canada / United States Tax & Accounting
- Topic: W-8BEN quick questions
- Replies: 3
- Views: 1979
W-8BEN quick questions
Canadian citizen and resident will be taking distributions from a pre-tax 403b plan that she inherited from her deceased husband. She needs to fill out a W8-BEN to claim the 15% treaty withholding instead of the usual 30% on distributions. --They've told her that she needs to apply for an ITIN first...
- Tue Jan 26, 2016 9:39 pm
- Forum: Canada / United States Tax & Accounting
- Topic: Bump-up questions
- Replies: 4
- Views: 2106
- Tue Jan 26, 2016 4:40 pm
- Forum: Canada / United States Tax & Accounting
- Topic: Bump-up questions
- Replies: 4
- Views: 2106
Bump-up questions
Nelson, a few questions related to bump-ups at Cdn departure. Will be brief: 1) Is bump-up of CB to FMV at Cdn exit on principal residence for non-US persons by XIII(6) an AUTO bump, i.e. nothing needs to be done, automatic step-up? 2) Are you aware of any other AUTO bumps at departure besides Princ...
- Mon Jan 11, 2016 2:51 pm
- Forum: Canada / United States Tax & Accounting
- Topic: Cdn principal residence at departure&Treaty step up in b
- Replies: 2
- Views: 2235
- Mon Jan 11, 2016 2:13 pm
- Forum: Canada / United States Tax & Accounting
- Topic: Cdn principal residence at departure&Treaty step up in b
- Replies: 2
- Views: 2235
Cdn principal residence at departure&Treaty step up in b
Nelsona, here are some questions I have on the options available (both from Cdn ITA & US IRC domestic points of view and from Treaty point of view) to a departing non-U.S. person (i.e. non-U.S. citizen and non-green card holder) with respect to their Cdn principal residence at the time of Canadi...