Hi again,
Sorry to add another wrinkle to this debate of mine. I get the rules on how self directed discount broker accounts work when moving to the US and becoming a tax resident there. You have to shut them down due to US rules. Except for maybe a RSP.
I was informed that if you didn't want to go through all the hassle of closing these accounts ASAP when you move, you could move all of the assets over to what was called an advisor account, pay your management fee, and the equities can remain as is. And if things look like they will go well in the US, you can transfer the assets or the value of it at that time and not liquidate everything at once. My questions are:
1) Under US rules, is having an advisor account permissible/legal?
2) If they are legal, what are the tax implications? Is having one of these enough to make you a tax resident of Canada even when living in the US? And if they are allowed, I assume any dividend income would be taxed in the US?
I last worked in the US under a TN about 15 years ago. Little money back then, a lot more now so things get a bit more messy. I'm getting the feeling I probably should be hiring a professional accountant to look into all of this!
Thanks for your help.
Discount Broker/Advisor Accounts
Moderator: Mark T Serbinski CA CPA
1. Yes, that is why they suggested it, It is a no buy account.
2, Finanacials are never a residential tie. everything would be taxed in US, sicne you would have already paid deemed disposition tax in Canada, Cdn dividends would have cdn NR tax withheld,
2, Finanacials are never a residential tie. everything would be taxed in US, sicne you would have already paid deemed disposition tax in Canada, Cdn dividends would have cdn NR tax withheld,
nelsona non grata. Non pro. Please Search previous posts, no situation is unique as you might think. Happy Browsing 
Related question.
I have TFSA/Cash accounts held under TD Direct. I've sold and withdrew the assets before I moved from Canada to US last year. However, there are still some small cash remaining (from dividends posted after, or fee rebates) in the accounts for a sum of about 400.
Is it ok to just keep them as-is? Will they need to be reported to US?
I have TFSA/Cash accounts held under TD Direct. I've sold and withdrew the assets before I moved from Canada to US last year. However, there are still some small cash remaining (from dividends posted after, or fee rebates) in the accounts for a sum of about 400.
Is it ok to just keep them as-is? Will they need to be reported to US?
Thanks.
But even with a small sum of 400? I thought FBAR requirement is aggregated sum of US10000 or more.
For the closing of TFSA and non-registered accounts, given that I'm already into 2017 does that also mean FBAR will need to be reported next year as well? So I just need to make sure I close it prior to 12/31/2017 right?
But even with a small sum of 400? I thought FBAR requirement is aggregated sum of US10000 or more.
For the closing of TFSA and non-registered accounts, given that I'm already into 2017 does that also mean FBAR will need to be reported next year as well? So I just need to make sure I close it prior to 12/31/2017 right?
So you have no other Cdn accounts? the TFSA is still a 3520 trust account. and yes, the fact that you left it open in now maens reporting it in 2017, as a trust and as a foreign account.
The non-registered account isn't a trust, but it is a nuisance, since you can't trade in it. Why keep it open?
So, you forgot to close the accounts in 2016, so your solution is to wait until the end of 2017 to do it? Hmmm.
The non-registered account isn't a trust, but it is a nuisance, since you can't trade in it. Why keep it open?
So, you forgot to close the accounts in 2016, so your solution is to wait until the end of 2017 to do it? Hmmm.
nelsona non grata. Non pro. Please Search previous posts, no situation is unique as you might think. Happy Browsing
My intention of leaving it open until end of 2017 is just in case I move back. Who knows what would happen to TN/NAFTA so. I misunderstood previously, I thought I only had to sell the assets and move the money outside of the account so US will not consider the gains for tax purpose, as well for the departure tax on Canada.
I have checking/saving and RRSP/locked-in RRSP accounts as well in Canada. I'm assuming these will now need to be counted towards the FBAR filing?
I have checking/saving and RRSP/locked-in RRSP accounts as well in Canada. I'm assuming these will now need to be counted towards the FBAR filing?
IRS considers deemed disposition due to departure from Canada as a reset on the cost basis. No need to actually sell.
The real reason to close your account is that you cannot trade in it legally, so most brokerages insist. You can transfer the stock holdings to a US brokerage.
As you concluded correctly, the sum of ALL your accounts make up the threshold, and once that is reached, ALL accounts need to be reported, even if they are empty.
The real reason to close your account is that you cannot trade in it legally, so most brokerages insist. You can transfer the stock holdings to a US brokerage.
As you concluded correctly, the sum of ALL your accounts make up the threshold, and once that is reached, ALL accounts need to be reported, even if they are empty.
nelsona non grata. Non pro. Please Search previous posts, no situation is unique as you might think. Happy Browsing
RE: "the TFSA is still a 3520 trust account". No CPA to this date has proved that such statement is true and to the contrary a tax lawyer has proven that under US tax law such is not true and that TFSA does not require foreign trust 3520 reporting. IRS too has never disclosed their position on this topic. Taxpayers who do file 3520 for TFSA (which IRS receives, ignores and then shreds, they don't even have the manpower/funding to run their US centers for the public to be open to the public on walk-in basis) do so only on cautionary basis of what-if IRS treats as FT...