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I Am A Canadian Citizen Who Moved To The US A Few Months Ago. We Were Not Able To Sell Our Residence Before We Left, And We Are Selling Now....
User Photo Michael Atlas, CPA, CA
Tax Professional Level: Tax Enthusiast

No, you are not! Selling it before you left would have been easier, because you would not have had to deal with CRA tax clearance requirements. However, the gain should be tax-free in Canada under the “principal...   Read More
I Am A US Citizen And Resident. I Own 1/3 Of The Shares Of A Private Canadian Corporation In The Manufacturing Business. I Have Agreed To...
User Photo Michael Atlas, CPA, CA
Tax Professional Level: Tax Enthusiast

If the shares you own are common shares, it is actually a “purchase for cancellation”, rather than a redemption, since common shares would not normally be redeemable. However, the tax results are the same in...   Read More
I Am A Canadian Who Owns 20% Of A US LLC Earning US Rental Income. The Other 80% Is Owned By Unrelated US Residents. Every Year I Get A US...
User Photo Michael Atlas, CPA, CA
Tax Professional Level: Tax Enthusiast

Definitely not! The LLC is not legally a partnership, and not treated as such for Canadian tax purposes. It is a corporation for Canadian tax purposes. Assuming that the other 80% is held by unrelated US residents,...   Read More
I Am A Canadian Expat Who Has Been Living Down In Atlanta Georgia Since 2008. Starting In 2009, I Stopped Filing Canadian Tax Returns...
User Photo Michael Atlas, CPA, CA
Tax Professional Level: Tax Enthusiast

No you are not! There is absolutely no legal requirement to submit form NR73 to the CRA in order to be a non-resident of Canada. If you are a resident alien of the US, and have no permanent home available in Canada,...   Read More
I Am A Canadian Citizen Who Has Been Living In The US For The Past Six Years -I Am Here On A Work Visa.. I Will Be Returning To Live In...
User Photo Michael Atlas, CPA, CA
Tax Professional Level: Tax Enthusiast

No, you are not right. You should delay selling until after you return to Canada-that way you will not pay tax in either Canada or the US on the accrued capital gains. That is because of the fact that, for Canadian...   Read More
A US Citizen And Resident Individual Is Considering Gifting A Half Interest In His Ontario Cottage To His US Resident And Citizen Spouse....
User Photo Michael Atlas, CPA, CA
Tax Professional Level: Tax Enthusiast

You are correct. Under domestic law, the “spousal rollover” is only available in connection with transfers between Canadian residents. The special rule in Article XXIX-B:5 of the Canada-US Tax Convention only...   Read More
I Am A Canadian Citizen And Resident, And I Recently Received A Payment Out Of A (conventional) IRA That My Late Uncle Had. He Was A US...
User Photo Michael Atlas, CPA, CA
Tax Professional Level: Tax Enthusiast

The IRA would be considered a “pension”, for the purposes of Article XVIII of the Canada-US Tax Convention, because it is a type of “retirement arrangement”. The US can levy its full statutory tax rate of...   Read More
I Act For A Canadian Corporation That Is Buying All The Shares Of Another Canadian Corporation, That Is A Metal Fabricator, From Its US-...
User Photo Michael Atlas, CPA, CA
Tax Professional Level: Tax Enthusiast

Yes, the lawyer appears to be correct, and no tax clearance from the CRA should be required. The tax clearance and notification requirements in connection with property acquired from non-residents (section 116 of...   Read More
I Have A US-based Client Who Did Some Computer Consulting In Canada Via His S Corporation, And There Was 15% Canadian Tax Withheld....
User Photo Michael Atlas, CPA, CA
Tax Professional Level: Tax Enthusiast

It sounds like what happened was that 15% Canadian tax was withheld under Regulation 105. Under that provision, where any amount is paid to a non-resident of Canada for services rendered in Canada, 15% tax must be...   Read More
Being Canadian, What Are The Implications Of Dissolving A U.S. State Of Florida Trust?
User Photo Michael Atlas, CPA, CA
Tax Professional Level: Tax Enthusiast

Since you are a Canadian resident, you have to concern yourself with both Canadian and U.S. tax issues. My comments will be confined to Canadian tax...   Read More

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