Search found 291 matches
- Thu Dec 27, 2018 9:13 pm
- Forum: Canada / United States Tax & Accounting
- Topic: 3520-A Penalty
- Replies: 23
- Views: 18249
Re: 3520-A Penalty
note that a number of practitioners believe that TFSA is not a foreign trust and therefore not subject to 3520 filing at all. This argument provides one avenue of push-back. In fact, you can google and find template letters to IRS on web spelling out the reasoning and citations for such argument, a ...
- Thu Dec 27, 2018 9:09 pm
- Forum: Canada / United States Tax & Accounting
- Topic: non resident filing jointly and FBAR
- Replies: 4
- Views: 2283
Re: non resident filing jointly and FBAR
If outside the USA for 12 mos, can file obamacare exemption form (Code C) and be exempt from health care tax; if using tax software, once you input that info, it will zero out the tax.
- Tue Jun 12, 2018 7:11 pm
- Forum: Canada / United States Tax & Accounting
- Topic: Taking stab at 3520, -A for TFSA
- Replies: 157
- Views: 209052
Re: Taking stab at 3520, -A for TFSA
Why not simply take the view of many practitioners that TFSA (or RESP) do not require 3520 reporting at all? No one has proven that they do nor has IRS opined or commented on the matter.
- Mon Oct 09, 2017 1:50 pm
- Forum: Canada / United States Tax & Accounting
- Topic: matching RRSP deduction affected by yr of contribution, 8938
- Replies: 5
- Views: 2904
- Mon Oct 09, 2017 11:02 am
- Forum: Canada / United States Tax & Accounting
- Topic: matching RRSP deduction affected by yr of contribution, 8938
- Replies: 5
- Views: 2904
- Sun Oct 08, 2017 11:03 am
- Forum: Canada / United States Tax & Accounting
- Topic: matching RRSP deduction affected by yr of contribution, 8938
- Replies: 5
- Views: 2904
matching RRSP deduction affected by yr of contribution, 8938
1. Can the XVIII(15) matching RRSP deduction be claimed for a non-commuter or ONLY for a commuter? 2. If said RRSP contribution was made entirely between Jan-March 2017 (claimed on the 2016 T1) can it be claimed on the 2016 1040 or must it only be claimed on the 2017 1040? 3. [unrelated to previous ...
- Mon Jun 26, 2017 9:50 pm
- Forum: Canada / United States Tax & Accounting
- Topic: Sale of US rental property
- Replies: 4
- Views: 2372
Google US Tax Toronto and look for a US tax specialist provider with many good Google reviews who does property rental/sale returns and outsource and/or arrange those 20 clients with that person. RE: As far as I understand, we can only claim expenses on the current year tax return, just be aware tha...
- Mon Jun 26, 2017 9:37 pm
- Forum: Canada / United States Tax & Accounting
- Topic: Form 8833
- Replies: 3
- Views: 2440
Reg (tax law) says (no): (c) Reporting requirement waived. (1) Pursuant to the authority contained in section 6114 (b), reporting is waived under this section with respect to any of the following return positions taken by the taxpayer: (v) That income of an individual is resourced (for purposes of a...
- Wed Mar 08, 2017 3:42 pm
- Forum: Canada / United States Tax & Accounting
- Topic: auto extension for Cdn partnership
- Replies: 0
- Views: 2408
auto extension for Cdn partnership
A Cdn partnership required to file 2016 1065 that keeps records in Canada, now due March 15, 2017 (third month), what citation can prove that 1.6081-5 - Extensions of time in the case of certain partnerships can be applied [I see where H. R. 3236 addresses this for corps but not for partnerships], a...
- Sun Feb 26, 2017 9:52 pm
- Forum: Canada / United States Tax & Accounting
- Topic: 15% tax rate on pensions
- Replies: 12
- Views: 9718
- Wed Feb 08, 2017 7:34 pm
- Forum: Canada / United States Tax & Accounting
- Topic: CPP and SE 1040-T1 part year in each country and CPT56
- Replies: 1
- Views: 1367
CPP and SE 1040-T1 part year in each country and CPT56
Facts: one 1099-misc slip is ONLY income of USC-CDN dual citizen taxpayer (Sch C on 1040 and Business income on T1) and was issued by a US payer for services performed throughout the calendar year, exactly 4 months performed physically in the US (only) when taxpayer resided in USA (Jan-Apr) and exac...
- Tue Feb 07, 2017 8:02 pm
- Forum: Canada / United States Tax & Accounting
- Topic: Recent US Citizen - Want to confirm I am doing this right
- Replies: 8
- Views: 3022
Depends on whether "citizenship on application†OR “automatic citizenship
For example compare "a" in each of the below:
8 USC § 1433 - CHILDREN BORN AND RESIDING OUTSIDE THE UNITED STATES; CONDITIONS FOR ACQUIRING CERTIFICATE OF CITIZENSHIP
a) Application by citizen parents; requirements
A parent who is a citizen of the United States (or, if the citizen parent has died during the preceding 5 years, a citizen grandparent or citizen legal guardian) may apply for naturalization on behalf of a child born outside of the United States who has not acquired citizenship automatically under section 1431 of this title. The Attorney General shall issue a certificate of citizenship to such applicant upon proof, to the satisfaction of the Attorney General, that the following conditions have been fulfilled:
(1)At least one parent (or, at the time of his or her death, was) is a citizen of the United States, whether by birth or naturalization.
(2)The United States citizen parent—
(A)has (or, at the time of his or her death, had) been physically present in the United States or its outlying possessions for a period or periods totaling not less than five years, at least two of which were after attaining the age of fourteen years; or
(B)has (or, at the time of his or her death, had) a citizen parent who has been physically present in the United States or its outlying possessions for a period or periods totaling not less than five years, at least two of which were after attaining the age of fourteen years.
(3)The child is under the age of eighteen years.
(4)The child is residing outside of the United States in the legal and physical custody of the applicant (or, if the citizen parent is deceased, an individual who does not object to the application).
(5)The child is temporarily present in the United States pursuant to a lawful admission, and is maintaining such lawful status.
(b) Attainment of citizenship status; receipt of certificate
Upon approval of the application (which may be filed from abroad) and, except as provided in the last sentence of section 1448(a) of this title, upon taking and subscribing before an officer of the Service within the United States to the oath of allegiance required by this chapter of an applicant for naturalization, the child shall become a citizen of the United States and shall be furnished by the Attorney General with a certificate of citizenship.
8 USC § 1431 - CHILDREN BORN OUTSIDE THE UNITED STATES AND RESIDING PERMANENTLY IN THE UNITED STATES; CONDITIONS UNDER WHICH CITIZENSHIP AUTOMATICALLY ACQUIRED
a)A child born outside of the United States automatically becomes a citizen of the United States when all of the following conditions have been fulfilled:
(1)At least one parent of the child is a citizen of the United States, whether by birth or naturalization.
(2)The child is under the age of eighteen years.
(3)The child is residing in the United States in the legal and physical custody of the citizen parent pursuant to a lawful admission for permanent residence.
For example compare "a" in each of the below:
8 USC § 1433 - CHILDREN BORN AND RESIDING OUTSIDE THE UNITED STATES; CONDITIONS FOR ACQUIRING CERTIFICATE OF CITIZENSHIP
a) Application by citizen parents; requirements
A parent who is a citizen of the United States (or, if the citizen parent has died during the preceding 5 years, a citizen grandparent or citizen legal guardian) may apply for naturalization on behalf of a child born outside of the United States who has not acquired citizenship automatically under section 1431 of this title. The Attorney General shall issue a certificate of citizenship to such applicant upon proof, to the satisfaction of the Attorney General, that the following conditions have been fulfilled:
(1)At least one parent (or, at the time of his or her death, was) is a citizen of the United States, whether by birth or naturalization.
(2)The United States citizen parent—
(A)has (or, at the time of his or her death, had) been physically present in the United States or its outlying possessions for a period or periods totaling not less than five years, at least two of which were after attaining the age of fourteen years; or
(B)has (or, at the time of his or her death, had) a citizen parent who has been physically present in the United States or its outlying possessions for a period or periods totaling not less than five years, at least two of which were after attaining the age of fourteen years.
(3)The child is under the age of eighteen years.
(4)The child is residing outside of the United States in the legal and physical custody of the applicant (or, if the citizen parent is deceased, an individual who does not object to the application).
(5)The child is temporarily present in the United States pursuant to a lawful admission, and is maintaining such lawful status.
(b) Attainment of citizenship status; receipt of certificate
Upon approval of the application (which may be filed from abroad) and, except as provided in the last sentence of section 1448(a) of this title, upon taking and subscribing before an officer of the Service within the United States to the oath of allegiance required by this chapter of an applicant for naturalization, the child shall become a citizen of the United States and shall be furnished by the Attorney General with a certificate of citizenship.
8 USC § 1431 - CHILDREN BORN OUTSIDE THE UNITED STATES AND RESIDING PERMANENTLY IN THE UNITED STATES; CONDITIONS UNDER WHICH CITIZENSHIP AUTOMATICALLY ACQUIRED
a)A child born outside of the United States automatically becomes a citizen of the United States when all of the following conditions have been fulfilled:
(1)At least one parent of the child is a citizen of the United States, whether by birth or naturalization.
(2)The child is under the age of eighteen years.
(3)The child is residing in the United States in the legal and physical custody of the citizen parent pursuant to a lawful admission for permanent residence.
- Tue Feb 07, 2017 7:57 pm
- Forum: Canada / United States Tax & Accounting
- Topic: Should 8833 be filed when using CPT-56
- Replies: 7
- Views: 3677
- Thu Feb 02, 2017 11:24 pm
- Forum: Canada / United States Tax & Accounting
- Topic: Should 8833 be filed when using CPT-56
- Replies: 7
- Views: 3677
- Thu Feb 02, 2017 11:22 pm
- Forum: Canada / United States Tax & Accounting
- Topic: Discount Broker/Advisor Accounts
- Replies: 10
- Views: 3981