IRS taxes on Cdn funds/gains during year of move to US

[nelsona]

Just one final point on making the treaty election (which I do not recommend by the way, I merely stated it was an option): If you ever apply for US citizenship (which you can do after three years in US), you will be asked on the form whether you at any time after becoming an LPR called yourself non-resident for tax purposes. Youwoul have to answer yes if you makle the treaty election.

[nquery]

Yes i was reading about the consequences of making that election and i do not think it's a good idea either. Thus waiting until Jan 1, or even Oct 1 for that matter, to be a US tax resident is a no go for me. I am going to just MFJ and deal with the reporting. And I will technically move to the US arm of my company on Oct 1 and use that as my departure date for canadian tax purposes.

Thank you for all of your comments.

[nelsona]

You will probably need an accountant. you need to analyze if your comapny should be deem sold, wound-up, paid dividends BEFORE you move or you could get hit with big tax bill in both countries that you could not write off against one another.

You also have CCPC issues, I suspect.

[nquery]

This is not my company. I am currently an employee for the canadian sub-division of a US based publicly traded corporation. I will simply be hired by the US entity in the same role and based out of the states instead of Canada.

[nquery]

And maybe I should clarify that I am not doing this transfer solely to game the system for tax or any other purposes - we really have started moving to the states, including buying a vehicle, looking for a house to purchase, etc, etc.