More and more Americans give up their citizenship, 2014 is on track to be a record year

More and more Americans give up their citizenship, 2014 is on track to be a record year
  A significant number of people continue to surrendered their US citizenship or terminate their “long-term US residence” (for green card holders). There are 776 names on the list that the Treasury Department released Friday for the third quarter of 2014. That’s the third highest quarterly figure ever. The total number of ascetics published to ...

Local Client Base (under FATCA) Credit Unions in Canada – an update 1

By way of background, as per the Canadian IGA, credit unions can apply to be classified as a “local client base” financial institution. In this case, the credit union would be FATCA compliant by reporting to the IRS only the names of clients who are US residents – the names of clients who are US ...

FEIE Audit questionnaires

FEIE Audit questionnaires
IRS Audit Questionnaire 1 IRS Audit Questionnaire 2

PFIC Excess Distribution regime (Section 1291 Fund) – Form 8621 line by line 1

PFIC Excess Distribution regime (Section 1291 Fund) – Form 8621 line by line
We’ve see the basics of PFIC taxation in post Passive Foreign Investment Companies (PFIC) and Canadian mutual funds, although truth being told, it applies to PFICs anywhere, now let’s dig in – Let the brain damage begin The scenario is that John Doe (SSN: 000-00-0000). He bought share of the Safe Investment Inc, a PFIC on ...

Passive Foreign Investment Companies (PFIC) and Canadian mutual funds 2

Why are PFIC rules important for holders of Canadian mutual fund? Many American citizens living or working in Canada have invested in Canadian mutual funds – likewise, many Canadians who subsequently moved to the United States retained their Canadian mutual funds holdings. They likely are unaware of the PFIC rules. Consequently many American taxpayers holding ...

Form 8891 – an obituary

Form 8891 – an obituary
History Before April 15, 2002, and despite the fact that tax deferral for RRSPs was provided by the US Canada tax treaty of September 26, 1980, RRSPs didn’t have specific forms, hence 3520s and 3520-As were used by the minority of taxpayers wanting to be compliant with the rules relating to having an interest in foreign trusts. To these, a form ...

Former IRS Head Miller Unsure if FATCA’s Benefits Outweigh Costs

Former acting IRS Commissioner Steven Miller on October 6 said that while he hopes the Foreign Account Tax Compliance Act leads to less offshore tax evasion, he’s not sure if the benefits of the law will outweigh its costs. “I can’t even say with conviction that I’m sure, looking strictly on a cost-benefit basis, that ...

FATCA ‘Tormenting’ Taxpayers, Olson Says

By the time lawmakers and taxpayers have figured out whether the Foreign Account Tax Compliance Act was worth the trouble, it might be too late to undo any damage, National Taxpayer Advocate Nina Olson said October 7. “However much I’ve tried to figure out what on earth [FATCA] means, and the consequences of it, I ...

The IRS makes it easier for RRSPs to be elected as tax-deferred under US law

Original source: IRS Simplifies Procedures for Favorable Tax Treatment on Canadian Retirement Plans and Annual Reporting Requirements IR-2014-97, Oct. 7, 2014 WASHINGTON ― The Internal Revenue Service today made it easier for taxpayers who hold interests in either of two popular Canadian retirement plans to get favorable U.S. tax treatment and took additional steps to simplify ...

Le Treasury Department rend la vie plus facile aux détenteurs de comptes épargne retraite canadiens

Résumé: Le Treasury Department rends automatique l’élection de différer l’imposition des REER et FERR en vertu de l’article XVIII (7) de la Convention fiscale entre les Etats-Unis et le Canada.   Les « US persons » ne sont généralement pas soumis à l’impôt sur le revenu aux États-Unis sur les comptes de retraite individuels (“IRA”) jusqu’à ce ...