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Is It Really Tax (in)efficient To Run A USA S Corporation As A US Cit Living As A P.R. In Canada?
User Photo Claudia Ku CPA, CA, MBA
Tax Professional Level: Tax Enthusiast

One of the key considerations is whether the corporation would be carrying on a business through a fixed place or permanent establishment (PE) in Ontario, Canada. If so, the Canadian taxes at the corporate level...   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
My Client Left South Africa 5 Years Back. He Is Tax Resident USA (resident Alien) And His SA Pension Fund Pay Out Accrues Before Feb 2014 (...
User Photo Kathryn Morgan
Tax Professional Level: Master Tax Advisor

I have not checked the Tax treaty, but, normally what would happen in this situation is the client would include the income on his US tax return as if it was US pension or SSA benefits.  If the income he is...   Read More


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