PFIC rules update on Canadian mutual funds

PFIC rules update on Canadian mutual funds

Not an update in that the rules didn’t change, just an update in my reasoning. After reading the private ruling letter #200752029 in the context of PFIC rules, my opinions tilts even towards the idea that Canadian mutual funds are not corporations and as such...
Understand the US taxation of RRSPs and RRIFs

Understand the US taxation of RRSPs and RRIFs

The US tax system is a Citizenship Based Taxation, meaning that US citizens (and permanent residents) are taxed on their worldwide income wherever they live. By default, income earned in an investment account would be taxed. For instance, income realized within the...
IRS Customs Hold

IRS Customs Hold

I’ve seen much talk in the community of American abroad about the ability of the IRS: To prevent the issuance of a passport to delinquent taxpayers (currently not true, but when applying for a passport, the Department of State will inform the IRS of the address...
US Estate Tax May be Payable by Canadians

US Estate Tax May be Payable by Canadians

Canada-U.S. Tax Treaty Article XXIX B Taxes Imposed by Reason of Death A U.S. estate tax return must be filed if a deceased Canadian resident who is not an American citizen-owned U.S.-situated asset exceeding $60,000 fair market value at death.  However, if the...