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Tag Archive for Phil Hogan

Taxpayer Moved From Canada To The U.S. Has Problems With Canada Revenue Authority (CRA) Tax Notices

Phil Hogan - CRA Notices
Tax Question

I moved to the US from Canada 3 years ago and I’ve recently received some CRA tax notices that have been causing me problems. When I left in 2012 I neglected to tell my broker that I was moving. It wasn’t until the next year that I realized (because he told me) that I should have turned my account into a non-resident account and taxes should have been withheld and sent to CRA on my dividends.

After many months of going back and forth with CRA I managed to get the tax withholdings resolved. However now I have a different problem. I’ve also paid US tax on these dividends and now I have CRA notices telling me that I also have to pay tax on the same dividends. From my calculations I’m paying about 10% US tax and 15% Canadian tax on these dividends. Should I really be paying 25% total on dividends from Canada?

I tried to get some help from my US CPA but he keeps telling me that there’s nothing I can do and to just pay the CRA bill.

Is this really my only option? They also continue to withhold the 15% tax. Am I stuck with 25% tax. If so, should I move these investments to the US?

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IRS Expands Compliance Reviews In International Areas

Phil Hogan - IRS International Compliance Reviews

In 2018/2019 the IRS is expanding their compliance review in several international areas. We expect that our cross border clients will be receiving some additional review on these items. I have included a list of notable international examples below (see the full list here):

1120-F Delinquent Returns Campaign
Corporate Direct (Section 901) Foreign Tax Credit (“FTC”)
F3520/3520-A Non-Compliance and Campus Assessed Penalties
FATCA Filing Accuracy
Foreign Earned Income Exclusion Campaign
Forms 1042/1042-S Compliance
Form 1120-F Chapter 3 and Chapter 4 Withholding Campaign
Form 1120-F Non-Filer Campaign
Individual Foreign Tax Credit (Form 1116)
Individual Foreign Tax Credit Phase II
Nonresident Alien Schedule A and Other Deductions
Nonresident Alien Tax Treaty Exemptions
NRA Tax Credits
Offshore Service Providers
OVDP Declines-Withdrawals Campaign
Related Party Transactions Campaign
Repatriation Campaign
Section 965 Transition Tax

Phil Hogan

 

Canada Revenue Agency (CRA) Has Shared Over 1.6 Million Documents With The IRS To Date

Phil Hogan - Canada- US Cross Border Tax Issues

The Canada Revenue Agency (CRA) continues to supply information to the IRS on U.S. Citizen owned investment and bank accounts. According to CBC, CRA has already shared over 1.6 million Canadian banking records with the IRS. Even with the significant sharing of documentation we are still not seeing an increased level of new clients being contacted by the IRS.

You would think that if the IRS has such a large of amount of banking information from United States citizens abroad they would be enforcing compliance by reaching out to these Americans. This might be something that has yet to happen and may be on the horizon.

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