US source vs. Canada source for dual citizen

[rlb]

For a dual US-Canada citizen, now resident in Canada (since mid 2010), have I got these sources of 2011 income categorized correctly? Thanks.

1. US corporate pension: US source
2. US corporate final deferred compensation: US source
3. IRA withdrawal: US source
4. Interest on US accounts or bonds: US source
5. Dividends or capital gains of stocks of US companies: US source

6. Interest on Canadian accounts or bonds: Canada source
7. Dividends or capital gains of stocks of Canadian companies: Canada source

Also:

8. Am I correct that #5 is US source even if the stock was purchased through and held by a Canadian broker?

[nelsona]

capital gains of US companies are Cdn-sourced for all Cdn residents, regardless of what brokerage has them.

Only dividends from such companies are US-sourced.

[nelsona]

And just to clarify (4), while US interest is US-sourced, you cannot claim any tax credit in canada for any US tax that might arise from it, as it would not be taxed in US except for the fact that you are US citizen.

[nelsona]

You should also be ensuring that none of your US-sourced income held by Cdn brokerage is having tax withheld by that brokerage (including dividend tax), since you are not subject to it. You can get any of that back when you file your 1040.

[rlb]

Good thought, I'll keep an eye on it. However, brokerage is TD Waterhouse, pretty experienced in international accounts, and we gave both Canadian SINs and US SSNs when opening the accounts. I'm not sure whether they will send US 1099 forms or T3/T5 for the purchase but either should work OK when matched with the statements.

As you say, I will get back any incorrect withholding at filing time, and then have the opportunity to request it be done properly.

[nelsona]

Its just that you do not want your holding eroded out of your account by withholding if it is not necessary.