Search found 292 matches
- Wed Aug 17, 2016 10:18 pm
- Forum: Canada / United States Tax & Accounting
- Topic: Canadian sale of US property
- Replies: 4
- Views: 2575
and you don't want to be approaching depreciation recapture the same way you would on a Cdn return, as the US recapture rules apply, and work, quite differently, even though conceptually they are quite similar. Cd return recapture: A resident of Canada is subject to Canadian income tax on worldwide ...
- Wed Aug 17, 2016 10:06 pm
- Forum: Canada / United States Tax & Accounting
- Topic: Canadian sale of US property
- Replies: 4
- Views: 2575
- Fri Aug 12, 2016 3:21 pm
- Forum: Canada / United States Tax & Accounting
- Topic: US withholding on lump-sum pension payment - periodic?
- Replies: 3
- Views: 2644
I am mutli-tasking and am not entirely focused on your facts and findings but did want to point out these two links to you, let us know if helps. https://www.irs.gov/individuals/international-taxpayers/pensions-and-annuity-withholding https://www.irs.gov/businesses/the-taxation-of-foreign-pension-an...
- Sun Jul 10, 2016 11:21 pm
- Forum: Canada / United States Tax & Accounting
- Topic: W-7 ITIN for Spouse (Reason)
- Replies: 9
- Views: 6185
- Sun Jul 10, 2016 11:10 pm
- Forum: Canada / United States Tax & Accounting
- Topic: Trouble with 1116
- Replies: 15
- Views: 6990
- Tue Jul 05, 2016 10:33 am
- Forum: Canada / United States Tax & Accounting
- Topic: RRIF Withdrawals Taxed by IRS
- Replies: 10
- Views: 4991
- Tue Jul 05, 2016 10:28 am
- Forum: Canada / United States Tax & Accounting
- Topic: 8828 US real estate sold by spousal co-owners
- Replies: 2
- Views: 1730
Interesting, the Code (Section 1445 (5)(B) is actually clearer than the regulation, b/c the code says “realized for the propertyâ€, while Reg § 1.1445-2(d)(1) says “realized on the transactionâ€.
While from the Reg alone, I was inclined toward looking at the aggregate purchase price and not the amount realized per taxpayer and say that the Reg, when stating "the amount realized on the transaction" means just that. However, with the Reg using “Transaction“ one could argue that "the amount realized on the transaction" means on the transaction per each taxpayer. So, that Reg language alone isn't conclusive, at least to me.
In contrast, that argument can’t be made to say that “realized for the property†means per each taxpayer.
While from the Reg alone, I was inclined toward looking at the aggregate purchase price and not the amount realized per taxpayer and say that the Reg, when stating "the amount realized on the transaction" means just that. However, with the Reg using “Transaction“ one could argue that "the amount realized on the transaction" means on the transaction per each taxpayer. So, that Reg language alone isn't conclusive, at least to me.
In contrast, that argument can’t be made to say that “realized for the property†means per each taxpayer.
- Mon Jul 04, 2016 4:17 pm
- Forum: Canada / United States Tax & Accounting
- Topic: 8828 US real estate sold by spousal co-owners
- Replies: 2
- Views: 1730
- Mon Jul 04, 2016 4:05 pm
- Forum: Canada / United States Tax & Accounting
- Topic: 8828 US real estate sold by spousal co-owners
- Replies: 2
- Views: 1730
8828 US real estate sold by spousal co-owners
Would US real estate acquired by an individual for use as a residence, worth in aggregate over USD$300k (say $320k) and sold by NRA spousal equal co-owners (say $160k each) meet the 8288 filing exception for when one (or more) individual(s) acquire U.S. real property for use as a residence and the a...
- Mon Jul 04, 2016 3:58 pm
- Forum: Canada / United States Tax & Accounting
- Topic: CCRA being difficult about FTC for cross border commuters
- Replies: 24
- Views: 12115
- Wed Jun 29, 2016 4:50 pm
- Forum: Canada / United States Tax & Accounting
- Topic: CCRA being difficult about FTC for cross border commuters
- Replies: 24
- Views: 12115
Here are the key items requested by CRA. It made a request but didn't specify from whence to obtain the requested and what document qualifies as a source document to suffice. - CRA Form T2209 - CRA Forms T3, T5, T4PS, Schedule 4, 3, Form T2125 -Foreign tax returns prepared - Tax slip from USA employ...
- Tue Jun 28, 2016 10:15 pm
- Forum: Canada / United States Tax & Accounting
- Topic: CCRA being difficult about FTC for cross border commuters
- Replies: 24
- Views: 12115
- Tue Jun 21, 2016 7:44 pm
- Forum: Business & Personal Immigration to the United States
- Topic: How long can a Cdn visitor stay in USA?
- Replies: 3
- Views: 11021
How long can a Cdn visitor stay in USA?
How long can a Cdn visitor stay in USA? Is it 6 months? Pls ignore tax implications in your reply.
- Sun Jun 05, 2016 3:04 pm
- Forum: Canada / United States Tax & Accounting
- Topic: Switching filing status from one year to the next
- Replies: 7
- Views: 4032
- Sun Jun 05, 2016 3:01 pm
- Forum: Canada / United States Tax & Accounting
- Topic: Switching filing status from one year to the next
- Replies: 7
- Views: 4032