Hi, I'm fairly new to this, so please let me know if I'm omitting important information here.
<ul>
<li>I'm a dual citizen of Canada and the US</li>
<li>I live in Canada</li>
<li>I work for a Canadian company with T4 income and Canadian tax is withheld</li>
<li>I often travel the US for business (in 2014, was in the US for two thirds of my work days)</li>
<li>I receive dividend and interest income in both the US and Canada, but in 2014 did not receive any employment income in the US</li>
</ul>
The Canadian side of my situation seems fairly straightforward, but I'm very likely missing something there. The US side has me a bit confused. My understanding is that the US considers the 2/3 of my employment income for which I performed work in the US as US-source income. My question is whether I can still apply the foreign tax credit for taxes paid in Canada to nearly eliminate my US taxes due?
I'd appreciate any insight into my situation, and am happy to provide more information if it's needed.
Dual citizen, live in Canada, travel to US for work
Moderator: Mark T Serbinski CA CPA
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- Posts: 10
- Joined: Sat Mar 14, 2015 6:22 pm
- Location: Toronto
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- Posts: 10
- Joined: Sat Mar 14, 2015 6:22 pm
- Location: Toronto
It will depend on the days you spent in 2015. The taxability under that portion of the treaty is applied retroactively. Since for the period between mid-2014 and mid-2105 you have no doubt exceeded the 183 days, you are taxable in US for the entire period (and are taxable in the state).
So you cannot use the re-sourcing provision, since you fail to meet the XV.2(b).
It shouldn't be a big deal to you. the tax you pay in US will be credited on your Cdn return. If it isn't last year, taht ais because of the split-year, and should work out better for 2015 when it wil all be taxable in US.
So you cannot use the re-sourcing provision, since you fail to meet the XV.2(b).
It shouldn't be a big deal to you. the tax you pay in US will be credited on your Cdn return. If it isn't last year, taht ais because of the split-year, and should work out better for 2015 when it wil all be taxable in US.
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