Search found 754 matches

by JGCA
Sun Feb 01, 2015 11:05 am
Forum: Canada / United States Tax & Accounting
Topic: Canadian Corp paying US corp for work performed in US
Replies: 3
Views: 2400

No different from selling goods or services the income is earned in Canada for tax purposes since yur servers are probably located in Canada for the download then this will mean your income was earned in Canada for the small business tax also so on this you will qualify to claim the small business t...
by JGCA
Sat Jan 31, 2015 6:36 pm
Forum: Canada / United States Tax & Accounting
Topic: moving/working in US and selling family farm
Replies: 5
Views: 3100

YOu need to see a tax accountant to determin the huge capital gain on the farm. If indeed it is sheltered by the capital gains exemption say $ 750K or more based on the new budget the qualifying gain is only tax free in Canada the US will not recognize this so as was stated before sell it before you...
by JGCA
Sat Jan 31, 2015 6:28 pm
Forum: Canada / United States Tax & Accounting
Topic: Canadian Corp paying US corp for work performed in US
Replies: 3
Views: 2400

Your a CND corp that will have idependent sub contractors in the US as long as they can not negotiate the contracts on your behalf to imply your have a presence in the US then you merely invoice your client in the US and they invoice you in Canada for the work they performed on the project. Your CND...
by JGCA
Fri Dec 12, 2014 4:34 pm
Forum: Canada / United States Tax & Accounting
Topic: Incorporate in Canada?
Replies: 1
Views: 1439

Since you are a USC you will have to report not necessary file a 1120F to the IRS each yr since you own more than 10% of a fareign corp they want reporting on that at the least. 1) If you would incorporate you should pay salary only to reduce the tax in the corp and allow you to take the income pers...
by JGCA
Sat Dec 06, 2014 6:34 pm
Forum: Canada / United States Tax & Accounting
Topic: How to report sale of canadian growth fund
Replies: 4
Views: 2499

Yes Part 1 does have an exemption of $ 25K or $50K if you file a joint return for all PFIC funds if they are below this value you do not have to report the annual information in Part 1 of from 8621. If you are making elections you still must file Part 11 If you have income you still must file Part 1...
by JGCA
Sat Dec 06, 2014 12:34 pm
Forum: Canada / United States Tax & Accounting
Topic: How to report sale of canadian growth fund
Replies: 4
Views: 2499

THe FBAR mininum threshold of $10K is simply a reporting requirement that has to be filed, you now have sold this fund in 2014 you now have to report the gain on the sale since your original cost was low you have a capital gain to report on your 1040 on this sale also.
by JGCA
Sat Dec 06, 2014 12:30 pm
Forum: Canada / United States Tax & Accounting
Topic: Difference between distribution and disposition, 8621
Replies: 3
Views: 2567

These are rules for shareholders owning shares in passive foreign investment company holdings. As a shareholder you may own these shares directly in your name or through say a holding company that you also own ( this is indirect since its owned by an other entity that you own) as long as there is a ...
by JGCA
Fri Dec 05, 2014 5:32 pm
Forum: Canada / United States Tax & Accounting
Topic: Cross border tax question with Canadian Corporation
Replies: 13
Views: 5595

BASICALLY YES, the income is distributed to the USC regarless if he actually took it out or not so top match the FTC you would distribute it but no credit for the corp tax since its borne by the corp not the indivdual, this is why I said all along you should be taking salary so no tax is payable by ...
by JGCA
Thu Dec 04, 2014 10:15 pm
Forum: Canada / United States Tax & Accounting
Topic: Cross border tax question with Canadian Corporation
Replies: 13
Views: 5595

YES an ULC is traeted by CRA as a corp and IRS as a see through entity. The ULC can claim the SBD in Canada if the shareholders are CND residents. Note that only Alberta, NS and BC allow for these entities to exits and each has different requirements as to % of non resient shareholders. The IRS will...
by JGCA
Thu Dec 04, 2014 4:49 pm
Forum: Canada / United States Tax & Accounting
Topic: Cross border tax question with Canadian Corporation
Replies: 13
Views: 5595

yes basically you are forced to take it as salary to get the offset FTC so there is no use to form a CND corp in such a scenario.
by JGCA
Thu Dec 04, 2014 4:14 pm
Forum: Canada / United States Tax & Accounting
Topic: Cross border tax question with Canadian Corporation
Replies: 13
Views: 5595

ND is missing the point, you do not want to give him dividends that are passive income because he then pays tax at the full 27% rate in the corp and gets no FTC against this 27% in the US. If he chooses to go with a CND corp then all renumeration will be by way of salary so all tax paid personally i...
by JGCA
Thu Dec 04, 2014 3:17 pm
Forum: Canada / United States Tax & Accounting
Topic: Cross border tax question with Canadian Corporation
Replies: 13
Views: 5595

Your not eligible for the SBD corp tax rate in Canada of 13.5% BC because you will remain a US resident so by sec 125(7) of the ITA as a non resident controlling shareholder the corp will not qualify for the SBD rate on the first $500K of taxable income. Also note that by claiming a dividend this wi...
by JGCA
Thu Nov 20, 2014 3:02 pm
Forum: Canada / United States Tax & Accounting
Topic: Living in Canada & Consulting in USA < 183 days - tax
Replies: 4
Views: 2946

Just to clarify, I meant I have seen this type of income get booked as active business income incorrectly all the time and CRA is now starting to assess with penalties these type of files. Your accountant is suppose to know this this is basic tax 101 it has to be from Canadian sources to qualify not...
by JGCA
Thu Nov 20, 2014 2:50 pm
Forum: Canada / United States Tax & Accounting
Topic: Living in Canada & Consulting in USA < 183 days - tax
Replies: 4
Views: 2946

The 19% is what we call the small business corp tax rate on active business income earned in Canada, if the income comes from anywhere else other than Canada like USA, Europe then it does not qualify for SBD.

I have seen thgis more often than not.
by JGCA
Wed Nov 19, 2014 9:24 pm
Forum: Canada / United States Tax & Accounting
Topic: Living in Canada & Consulting in USA < 183 days - tax
Replies: 4
Views: 2946

Normally a B1 busines visa allows you to attend meeings, negotiate contracts etc no actual work. If you do plan on doing actual work for one specific client then a TN visa is needed. Since you have no permanent establishment in US and will be in the US less than 183 days in any 12 month period no US...