Search found 8 matches

by kenrousselle
Wed Jan 24, 2018 11:36 am
Forum: Canada / United States Tax & Accounting
Topic: CDN resident working for US resident firm as an employee
Replies: 1
Views: 1656

CDN resident working for US resident firm as an employee

Can anyone confirm that a CDN person working as an employee (not independent contractor) for a US resident firm (most work done in Canada, US and abroad), earning $50,000 US + and not spending more than 183 days in the US will continue to be subject to US source taxes and be able to claim a foreign ...
by kenrousselle
Mon Aug 14, 2017 2:16 pm
Forum: Canada / United States Tax & Accounting
Topic: How can I recover the US Taxes I paid.
Replies: 3
Views: 2405

How can I recover the US Taxes I paid.

I invested monies in a Canadian Limited Partnership that owned US rental property through a US LLC. The US LLC sold the property and allocated the income, capital gains and taxes paid on the rental property. (wound down). I paid closed to $29,000 in US taxes, but I'm cappted on how much FTC I can ge...
by kenrousselle
Wed Jul 19, 2017 5:02 pm
Forum: Canada / United States Tax & Accounting
Topic: Distribution of Canadian Partnership holding US Real Estate
Replies: 0
Views: 3380

Distribution of Canadian Partnership holding US Real Estate

I have a client who owners a small %'age of a Canadian LP that recently sold a US property. They received a T5013 with capital gains of $80,000, a negative rental loss of $6,500 and US taxes paid of $27,000. I assume by the amounts that the Canadian LP didn't file for relief of withholding taxes pai...
by kenrousselle
Tue Jul 26, 2016 2:28 pm
Forum: Canada / United States Tax & Accounting
Topic: CCPC Dividends
Replies: 8
Views: 3697

CCPC Dividends

No, you are correct, he's a Canadian Citizen.
by kenrousselle
Tue Jul 26, 2016 1:53 pm
Forum: Canada / United States Tax & Accounting
Topic: CCPC Dividends
Replies: 8
Views: 3697

CCPC Dividends

Thanks again. They have no other income as they are a shareholder in their husband's company for which dividends were declared. Based on all of the research I've done in this case, these dividends appear to be classified as Qualified Dividends based on the company being a qualified foreign corp. and...
by kenrousselle
Tue Jul 26, 2016 12:16 pm
Forum: Canada / United States Tax & Accounting
Topic: CCPC Dividends
Replies: 8
Views: 3697

CCPC Dividends

Thanks, however, they paid no taxes in Canada as the amount was low enough not to attract any personal taxes after personal exemptions and deductions.

Ken
by kenrousselle
Tue Jul 26, 2016 11:03 am
Forum: Canada / United States Tax & Accounting
Topic: CCPC Dividends
Replies: 8
Views: 3697

CCPC Dividends

Wouldn't they be characterized as Qualified Dividends as they meet the test of: Qualified Dividends Qualified dividends are the ordinary dividends subject to the same 0%, 15%, or 20% maximum tax rate that applies to net capital gain. They should be shown in box 1b of the Form 1099-DIV you receive. T...
by kenrousselle
Tue Jul 26, 2016 8:47 am
Forum: Canada / United States Tax & Accounting
Topic: CCPC Dividends
Replies: 8
Views: 3697

CCPC Dividends

Can someone tell me whether CCPC dividends received by a US Citizen living in Canada are taxable in the US? I believe they would be considered Ordinary Dividends not subject to the Foreign Earner Income Exemption, however, I'm not sure whether the Treaty exempts them from taxation. Any assistance wo...