Serbinski Accounting Firms

Very good point!

I'm probably wasting too much time on this, seeing that it won't even save me any tax on an "overall" basis.

Thanks again for all your help with this.

Thank you so much for the further follow-up on this.

I will have to see if my software automatically reduces the income by the deduction, or if I have to do this manually.

I have not read the canatech.pdf, thank you for pointing this out to me. I'm going to take a closer look at this. The google books link I previously posted touched on this briefly, but it was not nearly as detailed.

I tend to agree with your analysis that only the extra amount over and above 15% can be claimed on line 232. I did several more hours of research on this after my last post, and couldn't find anything definitive. This seems to be the closest thing we have to rely on.

I'm going to try and claim the amount over 15% on line 232 and see what CRA does. I'm also going to send in a cover letter explaining the position I'm taking to give them a chance to correct me.

I just came across the link below as well. The way I interpret this, is for the portion that can be deducted on line 232 (whatever amount that actually is), I would not actually consider that amount as a deduction under 20(11) and 20(12). Because of the unique circumstances with the Canada/US tax treaty, I would write something like “I'm relying on treaty article XVIV paragraph 5â€￾ instead.

I would only use 20(11) or 20(12) if I had more than 15% from a country that did not have a tax treaty with Canada or if the treaty rate was more than 15%. Does that make sense to you?

https://taxinterpretations.com/tags/113807

Fair enough. I really do appreciate you helping me out here. I will point out however that your original post used no such language. You said "So, the only time you would claim 232 is if your dividend tax rate as determined on your 1040 was more than 15%". If I had not inquired about this ...

I will report back for everyone after my return has been processed. I appreciate all your help. Make no mistake, by reading some of your other posts, it’s evident that you are one of the most knowledgeable cross border tax minds around. However, don't you think it would be more responsible to admi...

Ok thanks so much for explaining this further. Based on your original response, I assumed that I could not claim anything on line 232, because you did not specifically mention it, but then I subsequently came across the following post on this forum and got even more confused. https://forums.serbinsk...

Ah, thank you so much for pointing out this very important oversight on my part. Most of my div's are qualified and taxed at a much lower rate than 15%. So a deduction on line 232 is not even applicable to me. I do however have US source interest income, which I'm still not 100% clear on. Based on y...

Thank you so much for the tremendous explanation. 1) If I understand you correctly, for US source dividends on the Canadian side, I can take a FTC for 15% AND a deduction for the excess over 15% on line 232 (assuming of course that my US tax rate on the dividends is higher than 15% to begin with). A...

I’ve done my own research with the help of this forum and the internet and I think I know how this should be done, but I’m not 100% sure. I’m a US citizen living in Canada with interest, dividend and capital gain income from investments. My understanding of how this should be handled on my Can...

Hi ND, please see below.

http://www.bankofcanada.ca/stats/assets ... 015-en.pdf

https://www.irs.gov/individuals/interna ... ange-rates

Am I missing something on this, didn't seem right to me either?

Great thanks! For the average exchange rate what countries published rate do I use? I went to both the Bank of Canada website and the IRS website and they are different by about 5%. IRS website says 1.329 and Bank of Canada says 1.2787. This makes quite a bit of difference depending on which one I u...

US citizen living in Canada with an RRSP. Just converted RRSP to RRIF and started taking income. I was compliant filing 8891 every year until they stopped being required. I read on this forum that just the growth is taxable on US side and I have a choice to tax all the growth first, last or proporti...