Serbinski Accounting Firms

Hi,

Trying to wrap my head around the treaties.

I'm a US citizen, living in Canada about to receive Pension and Social Security from France.

In determining the Canadian taxation I look at the Canada/France tax treaty. This makes sense.

In determining the US taxation, I look at the US/France tax ...

Hello - will the CRA accept an FTC from the US when the tax liability is eliminated by way of the U.S. child tax credit? I can see both arguments - no foreign taxes were actually paid vs. there were taxes owing but they were "paid" by way of a credit.
Thanks!

Forgot about the non-resident beneficiaries....

Thanks for the response. Good comments.

Hi,

If I die as a US resident with an RRSP balance, the balance will get paid out (about 100K) with 25% withholding from Canada. I'm fine with that.

The estate won't need to file a 706 form because I won't be worth more than 5.5 million upon death.

Is the RRSP payout considered income for US ...

The depreciation was only taken during the years it was rented. No depreciation taken during personal use period.

I'm comfortable with the Canadian side, including foreign tax credits. I'm just stuck on the US side. I know that I'm dealing with a Sec. 1250 gain but I can't seem to figure out if ...

Hi and thanks in advance for your thoughts.

I'm helping a Canadian that sold a US property in 2016.

Facts are:

Purchased in 1995, rented it for 8 years. Filed 1040NR, claimed depreciation each year. He has record of loss carryforwards.

He stopped renting and it became his winter home. He used ...

Thanks. Valid point. I'm over the exemption limit so I always found it easier to just claim the FTC rather than exempt a portion and then figure out the remaining creditable taxes for FTC.

Mainly force of habit as well. US source income has rarely been an occurrence for me so it's always been ...

I think I got it now. It's just like when I have US source dividends and the 1040 taxes the dividends at more than 15%. I resource the dividends and claim an FTC to limit the US tax to 15%. Same concept.

The rest of my 1040 is all Canadian source employment income, interest and rental. I'll source ...

So T1 would show the employment income as foreign source so that a foreign tax credit could be picked up on the state and FICA taxes.

The 1040 shows the same income resourced to Canada, picking up Canadian taxes as FTC.

NY return - typical non-res return showing the employment income.

Just seems ...

Thank you. Makes sense.

The income was earned in NY... would NY recognize the treaty "re-source" and allow a credit for the provincial taxes paid?

Can a U.S. citizen, resident in Canada use XV 2(a) to exclude employment income on my 1040? I had $5,000 of U.S. source employment income in 2015. I live in Canada.