deemed disposition

beely · Post by **beely** » Tue Oct 11, 2011 2:38 am

I have a question about deemed disposition of stocks I had owned in Canada.

The tax that was paid on the capital gain, can they be claimed as foreign tax paid on Form 1116?
And more importantly, if I can, do I claim the year they were actually sold (since I still have them) or the year I move to US? Is there an expiry date which I can use them?

THank you so much

nelsona · Post by **nelsona** » Tue Oct 11, 2011 6:52 am

Deemed disposition does NOT qualify as a triggering event for US capital gains.

What happens in US is that you pay US cap gains tax with the deemed dispo value as your new cost basis.

There is a rev proc to follow to do this.

beely · Post by **beely** » Tue Oct 11, 2011 10:10 pm

sounds good
thanks nelson

i will search up that rev just for the record

nelsona · Post by **nelsona** » Wed Oct 12, 2011 8:26 am

IRS Rev Proc 2010-19
http://www.irs.gov/pub/irs-drop/rp-10-19.pdf