Now that I am set up in the USA, my mom has decided to move down here with me. Here are the facts ...
1. she is a widow.
2. she has a single brokerage account in her name with approximately 1.5M of publicly traded securities with a FMV of 1.1M.
3. she has two bank accounts (CND and USD) with approximately 75K.
4. she owns 1/3 share with brother and sister in deceased father's holding company (a canadian private company) which holds about 3.5M of publicly traded marketable securities (FMV 2.75M) and cash of 150K. The retained earnings are about 6M (no dividends have been taken from the company for the last 10 years (siblings won't talk to each other) and share issuance are 300 common shares (mother has 1/3) and 900,000 preferred shares (mother has 1/3) with a PUC of 200K and a FMV of 1.9M; and finally ....
5. mother has no RRSP of her own, but on dad's passing in 2006, she picked up his RRIF of 750,000.
6. Mother is 68. ....
OK ... so what she do?
FYI: she has spent time here and has no absolutley no intention of returning to her home, which she has already sold ..... so she has no real estate in Canada ...
thx ....
Mother is Emigrating from Canada to USA ....
Moderator: Mark T Serbinski CA CPA
Ok, so she can move.
So, now go see a cross-border tax specialst. Too many issues to be solved on the internet... and to much money for free advice.
.
So, now go see a cross-border tax specialst. Too many issues to be solved on the internet... and to much money for free advice.
.
After 20 years, I am severely cutting back on responses. Do not ask specifically for my help. There are a few others on this board that can answer most questions. All the best
Sure:
1. she is a widow.
2. she has a single brokerage account in her name with approximately 1.5M of publicly traded securities with a FMV of 1.1M.
3. she has two bank accounts (CND and USD) with approximately 75K.
4. she owns 1/3 share with brother and sister in deceased father's holding company (a canadian private company) which holds about 3.5M of publicly traded marketable securities (FMV 2.75M) and cash of 150K. The retained earnings are about 6M (no dividends have been taken from the company for the last 10 years (siblings won't talk to each other) and share issuance are 300 common shares (mother has 1/3) and 900,000 preferred shares (mother has 1/3) with a PUC of 200K and a FMV of 1.9M; and finally ....
5. mother has no RRSP of her own, but on dad's passing in 2006, she picked up his RRIF of 750,000.
6. Mother is 68. ....
So, off to a specialist.
1. she is a widow.
2. she has a single brokerage account in her name with approximately 1.5M of publicly traded securities with a FMV of 1.1M.
3. she has two bank accounts (CND and USD) with approximately 75K.
4. she owns 1/3 share with brother and sister in deceased father's holding company (a canadian private company) which holds about 3.5M of publicly traded marketable securities (FMV 2.75M) and cash of 150K. The retained earnings are about 6M (no dividends have been taken from the company for the last 10 years (siblings won't talk to each other) and share issuance are 300 common shares (mother has 1/3) and 900,000 preferred shares (mother has 1/3) with a PUC of 200K and a FMV of 1.9M; and finally ....
5. mother has no RRSP of her own, but on dad's passing in 2006, she picked up his RRIF of 750,000.
6. Mother is 68. ....
So, off to a specialist.
After 20 years, I am severely cutting back on responses. Do not ask specifically for my help. There are a few others on this board that can answer most questions. All the best
Not enough.
You need help and advice. Corporate compliance, estate tax, departure tax, gift tax, foreign corporation, RRSP and foreign trust reporting.
She either already has a pro (these all have issues even if she doesn't live in US), or absolutely needs one before setting foot in US, not internet help.
Why would I get involved with something she is already paying soemone to take care of.
I'm serious. You aren't helping your mother, no more than doing her cataract operation yourself.
You need help and advice. Corporate compliance, estate tax, departure tax, gift tax, foreign corporation, RRSP and foreign trust reporting.
She either already has a pro (these all have issues even if she doesn't live in US), or absolutely needs one before setting foot in US, not internet help.
Why would I get involved with something she is already paying soemone to take care of.
I'm serious. You aren't helping your mother, no more than doing her cataract operation yourself.
After 20 years, I am severely cutting back on responses. Do not ask specifically for my help. There are a few others on this board that can answer most questions. All the best
would it simplify things for you if her holdings in the family company were single class of common shares with PUC of $100.
In fact if you have put any of teh above items into a Holdco since your PUC is only $100 and did a tax free reorg and now are leaving Canada your facing pretty hefty departure tax, so no it would not simplify things at all, speak to the tax lawyer you paid $$ fees to to explain why not.
In fact if you have put any of teh above items into a Holdco since your PUC is only $100 and did a tax free reorg and now are leaving Canada your facing pretty hefty departure tax, so no it would not simplify things at all, speak to the tax lawyer you paid $$ fees to to explain why not.
JG
As your Mom is a US citizen, she absolutely must have been filing US tax returns and FBAR forms, as well as Canada tax returns. Has she had a specialist doing this for her? If she has not been doing that, she must get into compliance with her US filing obligations immediately, as she has assets large enough to be a target for large penalties.
nelsona wrote:
"Corporate compliance, estate tax, departure tax, gift tax, foreign corporation, RRSP and foreign trust reporting." .. thx. I agree.
"She either already has a pro (these all have issues even if she doesn't live in US), or absolutely needs one before setting foot in US, not internet help." - all income was earned in Canada and IRS filing was done based on personal income tax prepared ... but above response clarifies issues ... so thanks ...
"Corporate compliance, estate tax, departure tax, gift tax, foreign corporation, RRSP and foreign trust reporting." .. thx. I agree.
"She either already has a pro (these all have issues even if she doesn't live in US), or absolutely needs one before setting foot in US, not internet help." - all income was earned in Canada and IRS filing was done based on personal income tax prepared ... but above response clarifies issues ... so thanks ...
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blairgoates
- Posts: 48
- Joined: Thu Apr 14, 2011 12:35 pm
"all income was earned in Canada and IRS filing was done based on personal income tax prepared"
Nelsona writes: "See. You need help already."
Blairgoates writes: "I hope the holding company is not a controlled foreign corporation."
I do not see what the issue is. Mom (born in the USA) as Canadian files a canadian return based on income received. She then files US return based on Canadian income received and declared. The company involved is based on estate from father (who moved to canada and set up company some 25 years ago). Is anyone implying that she has to report income in a Canadian company that she is a shareholder of, even though she has not received any income distribution?
Nelsona writes: "See. You need help already."
Blairgoates writes: "I hope the holding company is not a controlled foreign corporation."
I do not see what the issue is. Mom (born in the USA) as Canadian files a canadian return based on income received. She then files US return based on Canadian income received and declared. The company involved is based on estate from father (who moved to canada and set up company some 25 years ago). Is anyone implying that she has to report income in a Canadian company that she is a shareholder of, even though she has not received any income distribution?