Receiving a Bequest from Abroad If the value of aggregate foreign gifts that you receive during any year exceeds $10,000, you must report each foreign gift to the IRS. (The $10,000 figure will be increased for inflation after 1996.) A foreign gift is any amount you receive from a non-US person, which you treat as […]
Controlled Foreign Corporations (CFC’s) U.S. Citizens and Lawful Permanent Residents (i.e. Green Card holders) have unique income tax obligations, regardless of their country of residence, they must file United States income tax returns and international information returns annually. The U.S. income tax system is based on citizenship and lawful permanent resident status not just on […]
Tax Treatment for Persons Giving Up U.S. Citizenship to Avoid Taxation Internal Revenue Code – Section 877A The Heroes Earnings Assistance and Relief Tax Act of 2008 (P.L. 110-245) fundamentally changed the rules aimed at preventing expatriations in order to avoid U.S. tax by passing Code Sec. 877A. Unlike the old regime, which tracked an […]
Under the Affordable Care Act, the federal government, state governments, insurers, employers, and individuals are given shared responsibility to reform and improve the availability, quality, and affordability of health insurance coverage in the United States. Starting in 2014, the individual shared responsibility provision calls for each individual to have minimum essential health coverage (known as […]
Internal Revenue Service has concentrated efforts in recent years to ensure reporting of the existence of foreign holdings, and of income earned abroad or through foreign assets. Increasing numbers of U.S. taxpayers (U.S. citizen, green card holder, or lawful permanent resident of the U.S, or an entity established within the U.S., or which is owned […]
If you have retained a rental property in Canada while becoming a non-resident, Part XIII of the Income Tax Act levies a 25% withholding tax from the gross income from rentals. Section 216 Election (Canada) The purpose of section 216 is to extend to non-resident persons the privilege of paying tax on their net income […]
Paying or Receiving Child Support – Across the Border If you are a Canadian contemplating work or residence in the U.S. or an American planning to work or live in Canada, and are subject to the payment of Alimony or Child Support at home, the following will be of interest to you. According to Article […]
Changes to Replacement Residence Rules for Green Card Holders Although green card holders are generally subject to the same income tax rules as U.S. citizens, certain new proposed amendments would make life more difficult for U.S. citizens and green card holders who live in Canada. Under Canadian tax law, a “principal residence” is exempt from […]
(a) Leaving the United States Non U.S. citizens leaving the U.S. during a year and wishing to report their anticipated annual income during the year may file form 1040-C – U.S. Departing Alien Income Tax Return. The 1040-C is not a final return, and a 1040 or 1040NR must still be filed within the required […]
The Importance of Determining Residence income Since both countries have income tax laws dealing with the taxation of non-residents, it is important to understand the role that residence plays in determining the liability for income tax. (a) U.S. Residence Rules (i) Green Card Test Under U.S. law, persons who satisfy the “green card test”, including […]
