PFIC 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, my opinions tilts even towards the idea that Canadian mutual funds are not corporations and as such the PFIC rules shouldn’t...

Understand the US taxation of RRSPs and RRIFs

The US tax policy 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. Fortunately, income...

IRS Customs Hold

I’ve seen much talk in the community of American abroad about the ability to 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...

US Estate Tax May be Payable by Canadians

All amounts in this article are in US dollars 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 assets exceeding $60,000 fair...