Serbinski Accounting Firms

OK ... it seems there should be a way out of this, but I have yet to find one. Here's the scenerio. 1) Taxpayer (US Citizen) moved from US to Canada 11 years ago. Expected to stay in Canada indefinitely. Entire family moved to Canada. No question on residency ... Canadian residents. 2) Taxpayer reta...

[quote=nelsona post_id=51628 time=1553696452 user_id=30] And by filing 1040 reporting world income, she doesn't file 1040NR. [/quote] ... but by referencing the filing under XXV(1), this prevents her from getting caught up in FBARs and the likes, right? [quote=nelsona post_id=51627 time=1553696376 u...

Thanks for the response, @nelsona. That sounds like a fair approach (ie. to file the 1040 that it's a XXV(1) filing). We had been filing 1040NRs for years, until the IRS contacted her to indicate that she had never properly given up her Green Card (she just let it expire instead of filing the approp...

I'm trying to understand the application of Article XXV for an individual who is resident in Canada. Here's the scenerio: Canadian citizen Canadian resident US pension (effectively connected) = $1.4k US SS = $10k Canadian OAS = $6k In prior years, she paid no US tax since her exemption of $4k was hi...

What used to be paragraph 4 is now paragraph 3, since paragraph 2 was deleted in the 2007 amendment.

"2. Paragraph 2 of Article XXV (Non-Discrimination) of the Convention shall be deleted, and paragraphs 3 to 10 of Article XXV shall be renumbered accordingly."

Well ... the information I just posted is correct with respect to the formulas, but incorrect with respect to the status of the taxpayer. Apparently this provision (XXV(3)) only applies to married individuals with income from employment. Perhaps someone can help me then with this: Would XXV(1) provi...

Adding my two cents to try to clarify the issues around "the formula" The theory behind the formula is merely to determine the tax RATE which would apply to ALL income if taxed as US citizens/residents, and then apply that tax RATE to the income on the 1040NR (ie. only the US source income...

We have a client with an immigration (to Canada) date of July 11, 2018. Both spouses retired from their employment on July 5, 2018. Both spouses received significant retiring allowances on July 28, 2018. Aside from any benefits from foreign tax credits, I can't find any reason why the retiring allow...

Well, Publication 519 lists interest that is exempt for non-residents. ========================================================== https://www.irs.gov/publications/p519/ch03.html Nonresident Aliens Nonresident aliens can exclude the following items from their gross income. Interest Income Interest in...

Doh! That's right. They changed rate to 0% years ago for Canadian residents.

I believe it's only certain types of interest (bank/bond, etc..) that's exempt to all non-residents.

Thanks for the reminder on the 0% rate though.

Taxpayer is not a US citizen or resident. Only income is non-effectively connected income, on which tax was withheld, so there's no balance due or refund. Last year, the IRS took a long time to process her return and paid s amall amount of interest. Is that interest considered not-effectively connec...

Again, for the benefit of future readers of this thread. I've received a response back from the school, and they have clarified why this program isn't on the "eligible" list for US student loans purposes. Apparently, since the are an "international college" and not a "univer...

A bit off topic from the FBAR question, but here's an additional question. I understand that a taxpayer isn't penalized if there's no balance owing so filing a 4868 when there is a refund (or nil) is redundant. However, I've generally filed the 4868 even if a client doesn't have a balance due becaus...

Wow! As much as I really appreciate and value your assistance and your opinion, I'm not sure how to respond to posts like that. It's your forum, so I guess that's OK. With all due respect, it just seemed out of place. In any event: 4:11pm post: I provided a link to the particular program, along with...

Here's another link to a list I had found previously, but it doensn't contain the "Status" column, so I'm not sure how valuable it is. https://ifap.ed.gov/ifap/fedSchoolCodeList.jsp Here's a direct link to the Excel file. https://ifap.ed.gov/fedschcodelist/attachments/1718FedSchoolCodeList...