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November 2001 CEN-TAPEDE - Taxation based on where you work, mortgage =
tax deductitble, Canada vs US, Mortgage Interest not Deducktable, Open =
vs Closed Mortgage, Mutual Fund Portfolio
QUESTION:
Could you please provide me with information on the SMITH MANEUVER?. A =
listener to your radio show tried to explain it to me, but was having a =
difficult time.
=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D
david ingram replies:
My November 2001 newsletter was first published in the North Shore News =
for the North Shore Credit Union in 1976. It then went into my =
Investment Guide and was republished about every two years until this =
last version in November 2001. =20
In 1981, Fred Snyder, presented the concept to a MacCauley Nicolls =
Maitland Real Estate Office as a method for Realtors to make more sales =
and get more listings. The manager Fraser Smith wrote Fred a letter =
thanking him for the talk.
The Smith Maneuver is a method of making your mortgage deductible. =
Several different methods follow the spot about Canadians who need to =
pay tax to the United States when performing services. =20
For instance, I gave a copy of this newsletter to my client yesterday =
afternoon because I wanted to show him how to make his mortgage =
deductible. He read the front page and it turned out that he had been =
working in the United States for five years and has renewed his L1A visa =
three times and because he is paid from a Canadian payroll, he has never =
filed a US tax return.
The company has no other office or employee in Canada but set the =
payroll up to pay him alone. He still performs 40% of his services in =
Canada so the L1A is justified. The immigration lawyer who got his L1A =
for him never told him that he had to file a US return and the Canadian =
CA who has prepared his returns for the last five years never mentioned =
it either. However, my new client is liable for large penalties for =
failing to file his US returns.
Read on and remember that this question and others can be answered every =
Sunday morning at 9 AM on 600AM in the Lower Mainland of BC. Those =
outside of BC can listen to the program live on the internet at =
www.600am.com. The Long Distance number is 1-866-778-0600 and the local =
number is (604) 280-0600
We are also doing weekly free seminars on making your mortgage interest =
or your summer cabin interest or your car interest or your motorhome =
interest or your sailboat interest or your credit card interest =
deductible every Thursday Evening at 7 PM at 1764 West Seventh in =
Vancouver. You have to phone (604) 731-8900 to register.
We are also presenting a "better" alternative to RRSP accounts.
Jonathon Chevreau wrote a comprehensive and very good article on =
mortgage interest as a deduction in the NATIONAL POST. It can be found =
at: http://www.freedomparty.on.ca/freedomflyer/ff35_12.htm=20
Hope this helps. I hate sending the answers in this format because it =
tends to get stripped out by a lot of virus checkers but it is =
comprehensive enough that it is worth losing some to get good stuff out.
=20
=20
=20
November 2001 =20
The CEN-TAPEDE
david ingram's US/Canadian Newsletter
108-100 Park Royal South, West Vancouver, BC, V7T 1A2=20
(604) 913-9133 (9 AM - 5 PM) - Fax 913-9123=20
DID YOU KNOW? -- TAXATION IS BASED UPON WHERE YOU WORK - NOT =
WHERE YOU LIVE.=20
=20
Canadians performing services in the United States, and in =
43 of the states in particular, are required to file the respective =
state return(s) and a US federal 1040NR or 1040 income tax return, even =
if their remuneration was paid from Canada. This applies, but is not =
limited to:=20
* Executives attending meetings in the US and, in =
particular, California,=20
* Service technicians servicing Canadian products under =
warranty,=20
* Salespeople selling Canadian products in the US,=20
* Journalists (eg. covering Canucks Hockey games, INDY =
races or O J Simpson trial),=20
* Horse trainers, race car mechanics
The above are exempt from tax up to $10,000 of earned income =
but the taxpayer must file returns to prove his or her exemption per =
Article XV. If you earned over $10,000 in the US, US taxation depends =
on where the employer gets its ultimate tax deduction for the wages paid =
out. If you are in the US more than 183 days, you are usually taxable on =
your world income.=20
=20
** Entertainers, actors, musicians, =
performers,=20
** Professional athletes, race car drivers, =
jockeys.=20
The above are exempt from tax up to $15,000 in gross earned =
income (which includes travel expenses) but still have to file the =
return to prove their exemption under Article XVI.=20
=20
*** Transport Employees, Truckers, Flight Attendants, =
Pilots if over $15,000.=20
Transportation employees are exempt from tax in most cases =
even if in the US for more than 183 days, if they are exercising their =
regular employment. They must, however, file the tax return to exempt =
the income.=20
=20
With Chartered Accountants, US Lawyers, and US CPA's as =
associates, I feel that the CEN-TA Group has the experience and the =
qualifications to look after most, if not all, US / Canadian tax =
problems.=20
=20
Contact George Hatton, CA, Sonja Clark, CA, CPA, LLB, D'Arcy =
von Schleinitz, David Ingram, or Gail Ritter at (604) 913-9133 - Fax =
(604) 913-9123 for US and CANADIAN INCOME TAX PREPARATION, ACCOUNTING =
and / or CONSULTATION.=20
Contact David Ingram for US Working Visas.=20
=20
MORTGAGE INTEREST AS A DEDUCTION=20
=20
People usually think that Americans have it all because they =
can deduct their mortgage interest and property tax on their income tax =
return. This is true. They can make these deductions, but to do so, =
most families give up a $7,000 standard deduction. This is fine if your =
mortgage interest is over $5,000 or so, but the practical fact is that =
90% of mortgages in the US are $50,000 or less and interest on $50,000 =
isn't enough to justify giving up the standard deduction.=20
=20
In addition, Americans might have to PAY TAX ON THE PROFIT =
when they sell their principal residence. If you have lived in the =
house for two of the last five years, there is a $250,000 per person =
exemption.=20
=20
The US deductions are not free. There is a future potential =
tax liability. The principal residence house profit can be taxable even =
if you did not claim the deductions.=20
=20
Canadians DO NOT PAY TAX on profits from the sale of the =
family home. AND, Canadians can re-arrange their affairs to make their =
mortgage deductible.=20
=20
HOW TO MAKE YOUR CANADIAN MORTGAGE INTEREST DEDUCTIBLE FROM =
YOUR TAXABLE INCOME=20
=20
(and maybe make a million on the side at the same time)=20
=20
It is useless if not downright dangerous to plan personal =
finances around "US", so let's get on with planning for "ME". We will =
either be divorced or a widow(er) or dead. We all have to plan for =
ourselves alone and assume the other person will be gone. Let's also =
make our decisions based upon investments that we understand as opposed =
to diamonds, or jewelry, or art or antiques, or strip bonds, or or =
or....=20
=20
We all know that indulging in consumer credit at high =
interest rates to purchase diminishing assets is a luxury we cannot =
afford. Compound this fact with the non-deductibility of that high =
interest and we come up with rule number 1: INTEREST PAYMENTS THAT ARE =
NOT DEDUCTIBLE ARE A NO NO!=20
=20
However, before I talk about how to make interest payments =
deductible, I want to point out that nothing can be deductible if you do =
not have a record of it. This whole subject makes me angry. If I start =
sounding like the movie "NETWORK", do not be surprised. People tell me, =
"lawyers cost too much" and then pay through the nose, because they did =
not consult a lawyer in time. They tell me that doctors cost too much =
and then find out just how much they do cost when they do not pay their =
medical premiums. People tell me that dentists cost too much and do not =
brush their teeth. But what really makes me angry is when they say that =
accountants cost too much and wander into my office or anyone else's =
office with a shoe box or garbage bag or attach=E9 case full of receipts =
with three different years on them. Why don't they do a basic sort... at =
least into years? It is this same person who will complain when we =
charge for sorting the receipts. All we have to sell is our time; if you =
use an accountant's time, expect to pay for it.=20
=20
Would you like to know the simplest way to look after your =
records if you are a commission sales person, farmer, fisherman, or just =
plain one man or woman business? It isn=92t tying you to a computer =
program. TRY THIS!=20
=20
KEEPING RECEIPTS THE EASY WAY=20
=20
Take over one drawer in a desk or vanity and get about 25 or =
30 # 10 envelopes. Label them with an expense item in your business or =
work: Gas, Oil, Hotels and Motels, parking, telephone, and so on. When =
you get home at night or to the office in the morning, merely empty your =
pocket, purse, etc. into the relevant envelope. Around Jan 15th of the =
next year, simply add up the contents of each envelope and write the =
amount on the outside of the envelope. Those are your expense items for =
your profit or loss statement or expense statement in either Canada or =
the United States.=20
=20
YOU DO NOT NEED DOUBLE ENTRY BOOKKEEPING FOR YOUR "SIMPLE" =
BUSINESS. The only reason for double entry bookkeeping is to try and =
stop people from stealing from you. If you have no employees, no one is =
stealing from you.=20
=20
If you are audited by the Internal Revenue Service (IRS) or =
the Canada Customs and Revenue Agency (CCRA), you have all the relevant =
receipts for their query neat and totaled. Best of all, when you go to =
your accountant or tax man to have your return prepared, you will not be =
paying $75 to $150 an hour to have someone else sort and add your =
receipts. When it comes to an audit, the auditor will prefer to have the =
receipts segregated in this manner.=20
=20
On the subject of why you should keep receipts, try this one =
on for size. We will pretend you earn $55,000 per year and are on the =
edge of a 45% marginal tax bracket. You take a business trip from =
Vancouver to Victoria. It costs $100 for the ferry there and back. You =
spend $15 for a meal on the ferry going and $30 for a meal there and $30 =
for a meal coming back (you meet a client on the ferry and buy him =
dinner); total expenses $175. If you do not keep these deductible =
receipts, you might just as well have torn up a =93seventy-five=94 =
dollar bill and thrown the pieces overboard.=20
=20
At least most of that trip was deductible. Even though you =
spent $175, you got $75 back in the form of a tax refund or tax you did =
not have to pay. It only cost you $100. However, one of the rubs in this =
life is that if you just decided to take your family out to dinner and =
spent $70, you would have to earn $120 and pay $50 tax to have $70 to =
pay for the dinner.=20
=20
=20
This is the best example to arrange your affairs to make =
them 'deductible'. WORK AT IT! If you do not, no one else will and you =
will pay three to four times as much for the same thing.=20
=20
By the way, the VISA / MC / AMEX receipt is NOT sufficient. =
The reason is that people going to lunch have been known to give the =
actual receipt to one person while the other person uses his or her VISA =
slip as a receipt. Both the CCRA and IRS insist on the actual receipt.=20
=20
=20
PAYING FOR A NEW CAR=20
=20
Try this. I will ignore any finance charges for the purpose =
of this example and assume everyone has the ability to pay cash, (the =
example is far worse with interest factored into the equation).=20
=20
A commission salesman buys a $24,000 Magic Wagon and it is =
used 75% of the time for business. He is able to write off $18,000 of =
the purchase price of the car and gets back at least $8,100 as a tax =
refund. The car cost $16,000 or so in out of pocket cash. Or the =
salesman would have to earn $30,000 and pay $14,000 tax to have $16,000 =
net to pay for the car. His neighbor buys an identical car and has to =
earn about $44,000 and pay $20,000 tax to have $24,000 left to pay for =
the car. Add in the differences in gas, oil, insurance and interest and =
the cost can easily be two or even three times more to pay for the =
non-deductible car.=20
=20
NOT KEEPING RECEIPTS IS EXPENSIVE!=20
=20
If you can't afford a new car and your salesman neighbor =
buys a new car every year, it is partly because the tax system is =
helping to pay for it.=20
=20
Although there is no doubt that a self-employed person is =
entitled to certain expenses, as is a real estate agent or even a sea =
captain, YOU MUST HAVE RECEIPTS. In 79 DTC 899, Judge Delmar Taylor made =
the ruling that although employees earning commissions were permitted =
deductions for certain expenses not deductible by other types of =
employees, it was incumbent upon them to maintain records and =
documentation in support of such expenses. When no documentary evidence =
was produced, the whole claim was dismissed. It should be noted that Mr =
P Litvinchuk had earned $47,700 in 1974 and claimed unvouchered expenses =
for "parking meters, drinks, pay phones, etc. of $2,400". He earned =
$55,570 and claimed $2,000 for 1975, and during 76, he earned $67,834 =
and claimed $600. The tax office offered $600 for 74, $600 for 75 and =
$300 for 76 and Mr Litvinchuk appealed to get his original claim. Judge =
Taylor gave him nothing.=20
=20
Many taxpayers seem to think that there is a reasonable or =
an `allowable' amount of 5%, 10%, 15%, etc. that the tax office allows =
without receipts. NOT SO! Although the policy of the tax office is to =
allow `something', they in fact do not have to allow anything as the =
previous case showed. (For more wonderful `real life' stories of tax =
cases, see my "The Ultimate Year Round Tax Book" which is also =
published by Hancock House). Certainly the amounts claimed by Mr =
Litvinchuk were small in relation to the earnings, but as you have seen, =
reasonableness does not enter into it.=20
=20
Tax Law is like Parking Meters=20
=20
Either you are over-parked or you are not. The fact that you =
were going for change for a $1,000 bill is irrelevant. You should have =
had a Magic Wagon with a built in change dispenser. The difference =
between over parking or speeding and income tax is that when they catch =
you for speeding, they do not go back three years and give you a ticket =
for every day you sped in the last three years. Income tax goes back =
three, four, up to eight years on a regular basis.=20
=20
And, when you get caught for speeding, you KNOW you were =
breaking the law. You would never tell the nice traffic officer, =
=93what do you mean, I can=92t speed here, I have been speeding here =
EVERY DAY FOR TEN YEARS, but, when the CCRA auditor suggests that you =
can=92t claim something, the first thing you will say is: =93I=92ve =
been claiming that for ten years and EVERYONE ELSE at the office has =
been claiming it as well.=94=20
=20
On the other hand, also in 1979, a Sea Captain, Paul Allen =
from Lunenburg, Nova Scotia, who was an employee, was allowed 100% of =
his truck expenses because it was used to transport goods to and from =
the boat and was used exclusively for boat related activities. He also =
used his car for business trips and was allowed 20% of his car. He had =
an office in his home which he used to interview prospective crew =
members and was allowed 10% of the expenses of his house and last but =
not least, he had spent $447 for a party at his house (he did not have =
receipts) and Judge J B Goetz allowed the total amount because the party =
was for crew members, suppliers and maintenance personnel.=20
=20
Obviously, the quality of the evidence, the mood of the =
judge, and the circumstances change in each and every case.=20
=20
I will now return to the subject of making interest =
deductible. Twenty-two years ago I was very heavily into rearranging =
peoples' finances to make mortgage interest deductible. The 1979 =
election of Joe Clark and the actual production of a mortgage interest =
deduction form with the tax return stopped the momentum. Lately, it has =
been rare for people to come in and pay their money to make their =
interest deductible. And this is strange, because of course the interest =
is usually three times what it was in 1977 and 1978. In fact, in 1978, I =
would get thirty people a month and now I get 20 a year. I guess that =
people just like paying taxes or maybe those that would have come in and =
paid a $300 fee have now figured it out themselves by reading my book or =
a prior edition of this newsletter. Or, maybe they just want to pay more =
tax.=20
=20
Our "deductible mortgage" program typically took four to =
five years to implement. Joe Clark's government was bringing the =
deduction in for mortgages up to $50,000 over a four-year period. The =
deduction was actually included on the 1979 Income Tax Form. But Joe =
Clark was defeated and so was the deduction.=20
=20
The biggest part of our mortgage interest deductibility =
involved purchasing some rental real estate (you need an outside source =
of income). I am proud to say that as well as making the house mortgage =
deductible, in most cases the rental real estate has gone up =
significantly. Some of our purchasers in Brampton realized $120,000 =
profits from $10,000 down and made their mortgage deductible at the same =
time.=20
=20
CANADA VERSUS THE UNITED STATES=20
=20
The mortgage interest situation in Canada is different from =
the US. In Canada, mortgage interest is not deductible where the =
mortgage was put on the house to buy it as a principal residence or as a =
seasonal cabin/chalet. On the other hand, we in Canada do not have to =
pay tax on the capital gains profit when we sell our house. In the =
United States, there is a standard deduction or a person may `itemize' =
deductions. Itemized deductions include mortgage interest, property =
taxes, medical and dental, and even income tax preparation fees. When a =
mortgage is getting small (because of age or buy down), it is possible =
that a family of six could have a larger standard deduction than the =
mortgage interest and property taxes works out to and they have to pay =
tax on the profit (capital gain) as well.=20
=20
And in the States, mortgage interest is no longer deductible =
on that part of a mortgage, which exceeds the original purchase price. =
So after years of saying that there has been less need of my type of =
service in the US, it has become obvious that the US's changing to a =
`more Canadian' type of system makes the following proposal appropriate =
for both countries.=20
=20
It used to be that all other interest in the US was also =
deductible. Your Sears interest was deductible, your Visa interest was =
deductible, and your mother's car loan was deductible. But all that has =
changed. With the rules `Canadianized' over a four-year period starting =
in 1986, US taxpayers can no longer claim all that interest. As a =
consequence, US taxpayers have to start rearranging their affairs in the =
same manner.=20
=20
HOWEVER, ANYONE WHO WANTS TO REARRANGE HIS OR HER AFFAIRS, =
CAN MAKE HIS MORTGAGE INTEREST AND CAR LOAN INTEREST, AND BOAT LOAN =
INTEREST DEDUCTIBLE. It helps if you are self-employed. But if you are =
not self-employed, the same results can be had with the ownership of =
rental property or a good mutual fund portfolio. It is also possible to =
make a million on the side while you are rearranging your affairs.=20
=20
KILL YOUR CORPORATION=20
=20
Oh, I almost forgot. If you are the proud owner of a =
one-person corporation, this will not work. In fact if you are the proud =
owner of a corporation, with the exception of a couple of very esoteric =
credits like Scientific Research Tax Credits (SRTC) or Flow Through =
Shares, you will pay MORE income tax with a corporation than without. In =
addition, you will pay an easy $600 to $1,000 more for tax and legal =
work per year.=20
=20
If you have a corporation, you should likely kill it, or at =
least put it on a back burner for a while until you get all your =
interest deductible. If you have a corporation for `insurance purposes', =
i.e. so that you can't be sued, forget it. The courts find it very easy =
to go after the major shareholder of a corporation where that =
shareholder is the only or chief employee and where the problem arose =
because of the actions of that employee/shareholder.=20
=20
SITUATION=20
=20
A dentist making $100,000 a year wants to buy a $100,000 =
sailboat but he has no cash. He could afford the $1,000 a month payment =
if he did 100% financing but he would have to make $2,000 a month and =
pay $1,000 tax to have $1,000 left over for the boat payment if the =
interest was not deductible. If the interest were deductible, he would =
pay the $1,000 a month interest and get a $500 per month cash deduction =
off his income tax.=20
=20
We will assume he has a $200,000 house with a $50,000 =
mortgage (Lives in Lunenburg or Prince Rupert, etc.). We will assume =
that his practice grosses $20,000 a month and that after all expenses, =
he has exactly $100,000 left as his earnings.=20
=20
As we have already discussed, if he puts a mortgage on the =
house to buy the boat, the interest is not deductible because the money =
was used to buy a boat and yacht interest is specifically forbidden as a =
deduction in Canada unless the boat is a full time working boat (could =
be a rental). In the US, if the original cost of the house was $100,000 =
and a new mortgage was put on up to $150,000 from the $50,000 that was =
outstanding, only interest on $50,000 would be deductible. If the =
original cost was $150,000 or over, than the interest on the whole =
$100,000 WOULD be deductible.=20
=20
But let's take the worst case scenario and assume the =
original cost of the house was $50,000 and the $50,000 loan on it now =
was used to put the kids through university and fix the roof and =
plumbing. Therefore, any increased loans against the house bears =
non-deductible interest.=20
=20
The dentist has $140,000 worth of expenses per year. The =
expenses are for rent, light, heat, telephone, labs, supplies, repairs =
to equipment, assistant's wages and dental technicians. If he were short =
money some week because a cheque from a dental plan was late, and he =
borrowed money to pay for the rent and his assistant's salary, the =
interest would be deductible.=20
=20
So what SHOULD the dentist do?=20
=20
First our dentist goes to his or her `creative' mortgage =
person or bank manager (Joan Marsh maybe at (604) 535-9981) and says, "I =
want to arrange a floating business loan for my practice as a dentist. =
The total amount of the loan may be as much as $100,000." The bank =
manager will usually say yes, because our dentist is going to give the =
bank a mortgage on the $150,000 equity in his house.=20
=20
Each month for the next year, our dentist deposits all the =
gross receipts of the practice into a term deposit. He takes out his own =
personal expenses only. EVERY SINGLE TIME HE NEEDS TO PAY A BILL FOR THE =
PRACTICE, HE BORROWS THE MONEY FROM THE BANK THROUGH HIS PRE-ARRANGED =
FLOATING BUSINESS LOAN. When the Term Deposit is up to $100,000 (or =
$114,000 including GST and PST), he takes the $114,000 out and pays cash =
for the boat. The net result is that there is deductible $114,000 loan =
against the business and every single cent can be shown to have been =
borrowed to pay business expenses. If our dentist or doctor or lawyer or =
accountant has any other non-deductible interest (such as the first =
$50,000 on the house), he can now use the boat as security to borrow =
more money for the business while he pays down the other non-deductible =
loan.=20
=20
HOW ABOUT A SHOE STORE?=20
=20
The owner of the store wants to buy a nice little one =
bedroom Condo in Winnipeg for $60,000. He has no money saved and the =
shoe store is just making it plus a little extra but he is already =
paying out non-deductible apartment rent of $650 a month. If he could =
pay $800 a month deductible interest instead of $650 a month =
non-deductible rent, he would be about $200 to $300 ahead each month =
because of the tax refund/deduction.=20
=20
What does he do? What DOES he do??=20
=20
Simple.... He stops paying his bills for a couple of =
months. Every cent coming in goes into a term deposit.... Every cent =
except for what he needs for personal expenses. When his creditors have =
yelled a couple of times he goes to the bank and borrows money to pay =
them. What does he use as security? He uses his term deposit of course. =
Depending upon the monthly gross of the business it will take six months =
to a year to get the $60,000 into the term deposit. Now he has cash to =
pay for the apartment. Of course the bank won't release it because it is =
security for their business loan.=20
=20
What does he/she do? He slyly suggests to the bank manager =
(Joan Marsh) that he will have a paid for condo and the bank could take =
the condo as secondary security as well as a charge against all the =
business assets. The net result, a $60,000 loan with the main security =
being a condo, BUT the money was not borrowed to buy the condo. Every =
cent was borrowed to pay rent on the business, pay staff, buy stock, =
advertise, etc. It is an absolute paper trail of source and application =
of funds. (For an example of about thirty tax cases on deducting =
interest, see my "THE ULTIMATE TAX BOOK, published by Hancock House =
Publishers Ltd.")=20
=20
So I repeat, anyone who is self-employed or owns a small =
business (proprietorship, not corporation), or WHO OWNS RENTAL PROPERTY =
or an income bearing portfolio, can make his or her mortgage deductible. =
It might not work in two years, it might take three, four, five, or even =
six years, but IT WILL and DOES WORK.=20
=20
This is how you do it. Let's assume you have rental property =
(If you do not, we could and will arrange for you to buy it and manage =
it for you and set up the following program). That rental property might =
be the first MURB you bought or even a ski chalet. When you have a =
business, are self-employed or have rent coming in, no one tells you in =
what order you have to spend your income.=20
=20
For instance, if not in this program and you had to borrow =
$1,000 to fix the roof on your rental property, WE KNOW `automatically' =
that the interest on the $1,000 loan is deductible. Where we have a =
problem in our mind is when we have the money available to fix the roof =
and I say "BORROW IT ANYWAY".=20
=20
The problem is that we have been conditioned by some =
antiquated accountant to keep our business and personal accounts =
separate or set up a separate account for our rental house. Then we are =
told to pay those bills out of that account. THAT IS THE WORST ADVICE =
YOU EVER RECEIVED ABOUT FINANCE (well maybe second to the advice to buy =
a whole life insurance policy). When you have a separate account and you =
have used all the money from the rent to pay the bills for the rental =
house, and you still need money to fix the roof on your own house and =
you borrow the money to fix your own roof, the interest is not =
deductible. But if you took the rent money received and paid cash for =
the roof, then borrowed the money to make the mortgage payment for the =
rental property, the interest would be deductible. The money from the =
rent, from the dental fees, from the accounting fees, from the shoe =
sales, is YOURS FIRST to do with as you please. YOU, and =93ONLY=94 YOU! =
decide what you are going to pay first. Unfortunately, we have been =
conditioned to pay "DEDUCTIBLE" bills first when we should be paying =
"NON DEDUCTIBLE" bills first.=20
=20
Look at the "flow through" for the first year of a typical =
MURB of which there were some 350,000 sold to investors so that they =
could CLAIM A RENTAL LOSS on their income tax return. Remember, a MURB =
is just a multiple unit residential building. MURB's still exist. They =
just do not have as much artificial tax deduction associated with them.=20
=20
A typical situation might be that you take in $11,000 rent =
and spend $17,000 and you are encouraged to do this by the Governments =
of both Canada and United States because it is cheaper for the =
governments to give you, the investor, a tax deduction then it is to =
provide subsidized housing. In this example, where are you going to get =
the $6,000 shortfall? You have to earn it or borrow it. If you borrow =
it, the interest is a deduction. Why not take the $11,000 rent and pay =
down your own mortgage by $11,000 and borrow the whole $17,000 to fund =
the rental property.=20
=20
Let's take another tack at it. (A little nautical term =
there).=20
=20
Let's say you want to open up a camera store or a shoe store =
or a store to sell western hats. You finally heard about urban cowboys =
and realized Stetsons are big business. Of course, they stopped selling =
three weeks ago, but you just found out about them so you are going to =
open up a store and sell western hats. You borrow $30,000 and purchase =
$30,000 worth of hats from the Stetson Company. In the next year, you =
pay out $6,000 interest, $12,000 rent, $15,000 for wages, $5,000 for =
other miscellaneous things and $2,000 for heat and light. You've spent a =
total of $70,000 with the expectation of selling some hats. At the end =
of the year you haven't sold one. Where did you get the $70,000 in the =
first place? You put a mortgage on your house. The money was borrowed =
for business purposes, voila, the interest is deductible, even though =
the loan is a mortgage registered against the house.=20
=20
George Hatton, CA, a Cartier Partner who works out of the =
CEN-TA location at Park Royal in West Vancouver read the above and =
wanted a caution put in here. He is right. George wrote, =93The =
concept works as well for a portfolio of Mutual Funds as it does for =
Real Estate. The difference is that the fund value changes daily and =
you (and the lender) know what that value is. Real Estate Values also =
change daily but you don=92t really know an exact value and it is a time =
consuming and expensive process to redeem real estate. On the other =
hand, if you have made an inappropriate stock loan, it is common for the =
Stockbroker or lender to call the loan when =93the lender=94 gets =
nervous, selling you out of your position, and leaving you in the =
position that you can=92t =93catch up=94. This is exemplified in the =
next case.=20
=20
STOCK SOLD (shares, not stock in trade)=20
=20
In 1985, Russell I Emerson lost his claim. He had purchased =
$100,000 of stock in 1980, with borrowed money. When the investment =
turned out to be bad, he sold the shares in 1981 and incurred a $35,000 =
loss. He claimed this loss in 1981 and deducted $17,500 as an allowable =
business investment loss. He also refinanced a $63,750 loan to pay off =
part of his previous loan. (Please note that the amount of the loan =
exceeds the loss and confuses the issue.) The tax office disallowed the =
interest expense on the grounds that the investment no longer existed =
(shares had been sold). Judge Cullen of the Federal Court -- Trial =
Division agreed with DNR. (In 1993, Canada's tax law changed to allow =
interest on business expenses when the business has been closed).=20
=20
Jumping back a couple of paragraphs, you will see that it is =
easier to think about it in terms of a store than in terms of a rental =
building. Remember, a rental house or a rental apartment, or a rental =
cabin, or a rental sailboat, or a rental motorhome or a rental airplane =
is a BUSINESS. So, (my English teacher will be rolling over in her =
grave) if you borrowed the whole $70,000, the interest would be a tax =
deduction.=20
=20
Let's look at the hat store in another light. You sold =
$20,000 worth of hats. If you used this against your $30,000 inventory, =
you would still have to borrow $10,000 and the interest would be a =
deduction.=20
=20
Besides covering business expenses you have had to live. You =
have needed more money for your personal living expenses. You have to =
eat and you have purchased a lot of booze to drown your sorrows since =
you are not selling many hats. The question: Where did you get the =
$10,000 for personal living?=20
=20
Well, if you borrow $10,000 for food, light and heat for =
your house, the interest is not deductible. NO - not one cent. So what =
should you do? What SHOULD you do? If selling hats has generated any =
income, you should be using that income to pay for your personal =
expenses, then borrow the money to cover the business expenses ( sound =
familiar, do you see the difference?). If you borrow money for personal =
needs such as food (both countries now), you have to use after tax =
dollars to pay the interest because the interest is not deductible. But =
if you borrow money for business purposes the interest is a deduction. =
Therefore, always charge your business expenses and use the money (cash =
flow) from your business to pay your personal bills. Anyone who is =
self-employed or who owns rental property should be following this plan. =
=20
Watch: At $40,000 a year if you pay out a $1,000 interest =
bill, which is not deductible, you have to earn $1,600 and pay $600 tax =
to have $1,000 to pay the interest.=20
=20
But!: If the same $1,000 interest is deductible, you will =
get a $400 refund for a net cost of $600.=20
=20
Non-deductible interest costs twice as much in earnings =
requirements as deductible interest at the lowest rates. At higher =
marginal tax rates, it can cost up to four times as much.=20
=20
=20
MEANWHILE, BACK AT THE RENTAL APARTMENT=20
=20
You just assumed that the first $11,000 should be used to =
pay the interest, the taxes and the repairs and maintenance on the =
rental unit. Does it have to? It's your money isn't it? You can do =
whatever you want to do with that money. You could take it and drive to =
Mexico City, you could buy a used Cadillac, Or you could use it to put =
your kids through school.=20
=20
You can do whatever you please with that money. What usually =
happens is that, because of your desire to keep detailed records, you =
set up a separate bank account for the rental property. The money goes =
into this account and you are probably putting in money from your salary =
to subsidize the payments. At the same time you borrow money to buy a TV =
set or a car or to take a vacation. You borrow the wrong money don't =
you?=20
=20
What you should be doing, of course, is using all of the =
money from your salary plus the $11,000 rental income to pay down your =
mortgage on your own principal residence. Remember, the money you earn =
from any and all sources is yours first. You make the decisions about =
what to do with it.=20
=20
Now you want to make your mortgage payments deductible. If =
you have a creative bank manager, and he or she can do a little =
mathematics (find one who can) and if you have an outside source of =
income, THIS is what you do. Assume that you have a $49,000 mortgage for =
this example.=20
=20
Assume your regular payments on the mortgage are $8,000 per =
year. If your outside source of income provides you with $11,000 which =
you apply to the non-deductible mortgage this year, you would reduce =
your non-deductible interest costs and you would reduce the principal of =
the mortgage. So, in the first year of this example use $11,000 you have =
grossed from this outside source (business or rental property) to make =
an additional payment on your personal mortgage.=20
=20
You must still pay the operating expenses for your small =
business or pay the mortgage and operating expenses for your rental =
properties. Where do these funds come from? You borrow them of course =
(perhaps using the new equity on your personal house as security), and =
now the interest is clearly deductible on that loan.=20
=20
Now, what has changed at the end of the first year? How much =
money do you owe at the end of the year? You owe $38,000 on your =
personal mortgage because the additional payment of $11,000 has reduced =
the principal portion of your mortgage. Because you borrowed the money =
to keep your small business operating or borrowed to keep the mortgage =
payments, taxes, insurance and repairs current on your rental property, =
you have another loan of approximately $11,000. You still owe $49,000. =
But the difference is that the INTEREST ON THE $11,000 is DEDUCTIBLE.=20
=20
(You may have noticed that I have taken no principal off the =
loan when we are paying $8,000 against a $49,000 balance. The reason is =
that this was originally written at the height of the interest rates =
when 15, 17, 19, and even 22% mortgages were floating around. 16% =
interest on a $49,000 mortgage leaves no significant principal =
reduction. Many people have still have 14 or 16% non-deductible second =
mortgages. The principle is very valid. It works even better if you have =
an older mortgage and are making significant principal reductions with =
your basic monthly payments.)=20
=20
=20
Today, many people have 14, 18 and 26% Visa Card or Second =
Mortgage interest rates. I know that today, Nov 8, 2001, I can get a =
mortgage in the 4 or 5% range and that most Vancouver mortgages are =
going to be $225,000 on a $350,000 or $600,000 house but this is a =
concept that can be used in Australia, New Zealand, Germany, =
Cornerbrook, Newfoundland, Coos Bay, Oregon, Chilliwack, Hope, Squamish =
and Port Alberni. My readers are in 120+ countries and lots of small =
towns and this is written for =93everybody=94.=20
=20
11% interest on $11,000 is $1,210. If you are in a 40% =
marginal tax bracket, you have changed your tax bill by 40% of $1,210 or =
$484 for this year and next year and next year and next year and next =
year and next year if that is all you do.=20
=20
However, if you do it again the next year, you can reduce =
your tax by another $500 and another $500 until the $49,000 =
non-deductible is a $49,000 deductible mortgage. 11% of 49,000 is =
$5,390. 40% of $5,390 is $2,156 less tax to pay.=20
=20
If we were starting with a $150,000 mortgage at 11%, the =
interest is $16,500 and 40% tax is $6,600. But it isn't just that =
simple. If you are trying to pay $16,500 non-deductible interest at 40% =
tax bracket, you have to earn $27,500 and pay 40% tax of 11,000 (.40 x =
27,500) to have $16,500 left to pay the mortgage. In terms of `earning' =
dollars, your mortgage is costing you 18.3333333%. Whereas, if it is =
deductible, it is only costing you 6.6% in `earnings'.=20
=20
If you are renting out property, take all the rent payments =
and apply them to your personal mortgage. At $1,000 per month rent, it =
would take about three years to pay off that $49,000 mortgage (assuming =
you are also making your regular payments).=20
=20
Every month you are turning non-deductible payments into =
deductible payments. This is one of the best reasons I know of for =
buying rental property. American readers might wonder what all the fuss =
is about. They should realize that the majority of `itemized deductions' =
is composed of mortgage interest and that when you claim itemized =
deductions, you lose the `standard' deduction. Wouldn't it be nice if =
you could get the `standard' deduction PLUS the mortgage interest as a =
deduction. Using the above technique, you can. And if you do, you will =
get out of the syndrome of deducting state tax one year and paying tax =
on the refund the next year because it was included in the itemized =
deductions.)=20
=20
If you have a rental house on which you are losing money, =
the cash loss (and in the US, depreciation, and in Canada, Capital Cost =
Allowance on a MURB) can be used as a deduction against other income. =
Therefore, if you are in a 40% tax rate (federal tax plus provincial =
and/or state tax plus city/county tax), and are `losing' $400 a month, =
you would get a $160 / month tax refund or a reduction in the tax you =
have to pay at the end of the year. Please note that we have added =
property taxes, repairs and maintenance, advertising, management and =
depreciation to the equation now.=20
=20
What do you do the second year? You take income from the =
rental properties and the normal mortgage payments and you apply both to =
your personal mortgage. At the end of the year you have paid (your usual =
$8,000 plus another $11,000) $19,000 against your personal mortgage. At =
the end of this second year, how much do you owe? $27,000 on the =
original mortgage plus $22,000 of secondary financing. Keep in mind that =
your regular payments are not reducing the principal materially. We are =
going for the tax refund. If you turn around and use the tax refund to =
reduce your borrowings, then the balance outstanding will reduce faster. =
=20
Follow the same procedure for the third and fourth years and =
apply the tax refunds and your borrowings have been reduced by $5,000 =
and your interest is all deductible.=20
=20
By now, you should be able to see how to buy your Florida =
Condominium, your place in the Gatineau Hills, your place in the Gulf =
Islands and use the rent to pay the mortgage on your place of residence =
and the interest you are paying becomes deductible. (There must be an =
expectation of profit, i.e., you must be able to show a structured cash =
flow projection where it is reasonable to expect that the type of =
property you are renting will make a profit in the foreseeable future - =
for more explanations on this point see my `THE ULTIMATE TAX BOOK', also =
by HANCOCK HOUSE and available `ahem' in `better' book stores - not now =
- try the Library.)=20
=20
Most people should be able to get rid of the non-deductible =
interest in 4 to 7 years. Perhaps you should purchase two places, or the =
house next door and use the rental income to reduce your mortgage. =
Whether or not the property increases in value, simply by making your =
present mortgage deductible, you would have enough cash flow to ensure =
that you wouldn't be losing any real money on rental property.=20
=20
If you are already paying out $5,000 a year non-deductible =
interest on your house, think about turning it into a deduction on your =
tax return. If you could reduce your taxable income from $60,000 to =
$55,000, what would happen? You would save $2,000 in income tax..... =
That $2,000 will fund $182 a month loss on a rental condominium.=20
=20
If your choice is between having a clear title house, living =
there safely and securely, plus buying either Government Savings bonds =
and/or and RRSP in Canada or an IRA / KEOGH PLAN in the States OR having =
a clear title house, putting a mortgage on it and buying a condominium =
in Florida -- you should buy the condo in Florida. Do you remember why =
you bought the IRA/RRSP? It was so that you would have enough money at =
age 60, 65 or 70 to take out and have a Florida, or a Hawaii, or a =
Nevada vacation. Well, the only way to guarantee you will have enough =
money for shelter, is to buy it today at today's price.=20
=20
But be careful. The following three cases point out the =
problems with deducting interest and show that it is important to have a =
proper paper trail.=20
=20
MORTGAGE INTEREST NOT DEDUCTIBLE=20
=20
In 1979, there were two cases, which I thought should have =
been allowed as well. In the Holman case (I was involved as agent), Mr =
Holman had borrowed money to build a new house. He used his old =
paid-for house as security. When the new house was finished and he had =
moved in, he rented out the old house. He then deducted the interest =
from the rental income. We argued that the net result of the loan was =
that Mr Holman got to keep the rental house, and would incur future =
capital gains tax and rental income tax. It was obvious that if Mr =
Holman had sold the old house, bought the new house for cash, and then =
bought back the old house with borrowed money, it would have been =
deductible. However, R. St-Onge, QC, of the Tax Review Board, ruled =
that the borrowed money was used to buy a personal residence, and the =
interest was therefore a personal expense and not deductible.=20
=20
Also, in 1979 Eva M Huber lost a similar case, which went =
one step further. In this case, Huber sold the old house, but carried a =
mortgage on it. She argued that her own mortgage interest was =
deductible as it was there to enable her to carry the income-producing =
mortgage (which I think sounds logical). J B Goetz of the Tax Review =
Board found her position untenable and disallowed the deduction.=20
=20
The reason that the previous two cases did not win is that =
they were judged on the 1979 Federal court loss by the Bronfman estate.=20
=20
In 1987, the Phyllis Barbara Bronfman Trust lost its =
interest claim after a 14 or 15-year fight involving 1969 and 1970 tax =
returns. Proving that might and money and the best lawyers and =
accountants do not always win, the Supreme Court of Canada ruled against =
the Trust. The Trust had many investments and when it came time to =
pay money out to the beneficiaries, the trust decided to borrow the =
money instead of cashing in investments, which it was holding. The =
trust then tried to deduct the interest (similar to the Cochrane Estate =
case). The Tax office turned down the claim. The Tax Review Board =
turned it down in 1978; the Federal Court turned it down in 1979. But =
the Federal Court of Appeal allowed the claim in 1983. The Supreme =
Court had the last word in 1987 when it ruled against the Bronfman =
Estate.=20
=20
DO NOT USE A HOLDING COMPANY=20
=20
I strongly advise you not to set up a holding company for =
your real estate investments. If you do, you can't use any of the =
deductions personally. It is usually impossible to buy a piece of =
property with little or nothing as a down payment and rent it out for =
the first couple of years and make a profit. In fact, in real terms, it =
usually takes about five to seven years for inflation to work its magic =
and a profit to come into the rental stream. And if you do make a profit =
with nothing down the first year, you either `stole' the property, or =
you have put a lot of time, energy or know how into making the property =
worth more for rental purposes.... Otherwise the tenant should have =
bought it for `nothing down'.=20
=20
If you pay cash, you will have a profit. But if you borrow =
the money for a down payment, you will lose money. If you borrow money =
to buy real estate and then put your assets into a holding company, =
there is no profit to use the loss up against because the holding =
company does not have a profit. You have to make the money from your =
salary and loan it to the holding company to keep the company going and =
you can't use the loss as a deduction on your tax return because it is =
just a loan to the holding company. You very specifically do not want a =
holding company.=20
=20
THE BANKER DID IT=20
=20
For several years I sent many clients to one particular =
banker to get their `creative' financing in place. The banker was also =
one of the company's bankers and we would kibitz occasionally, and I =
would ask him when he was coming in to get some advice. He would just =
laugh and I would leave it alone. Well when he retired five years later, =
he had amassed (in 1984) a net worth of $480,000 in real estate by =
following the methods used by the clients I had sent to him.=20
=20
I have had dentists, doctors, dress manufacturers, =
mechanics, short people, tall people, fat people, skinny people, special =
people, average people, and people I do not even like, follow these =
concepts successfully.=20
=20
The aforementioned banker was a total skeptic at first. "If =
it's so good, why isn't everyone doing it?" "Prove it to me", etc... All =
we did was keep on sending legitimate, quality clients to him and when =
he understood the concept, he went out and did it on his own. He started =
buying some of the `funny' deals himself. So if you go into a bank and =
explain what you want to the banker, you are doing that banker a favour. =
=20
I want you to make sure that when you borrow the funds from =
the bank to make payments on the rental condominium, or the rental house =
next door, that you can show that you borrowed the money and that it =
went to the trust company for the mortgage, or the municipality for the =
taxes or the insurance company for the insurance. When your tenant gives =
you a cheque for rent, I want you to show that you paid that money on =
your personal mortgage principal.=20
=20
OPEN VERSUS CLOSED MORTGAGE=20
=20
Sometimes people say that they cannot do this because they =
have a closed mortgage. It works best with open or annual or six month =
term mortgages.=20
=20
However, if you have a closed mortgage, you can usually pay =
off 10% extra on every anniversary date. If you pay regular payments, =
plus 10% extra each anniversary date, it will likely be paid off in six =
and a half years anyway. So, =93Never say Never!=94=20
=20
Sometimes people listen to me and assume that I am painting =
a perfect picture. When they go to their bank, trust co., credit union =
to pay off their mortgage, they are told there is a three-month penalty. =
They then stop and assume I am wrong or something because of the three =
month penalty.=20
=20
It is always worth a three-month penalty to convert an =
existing closed mortgage to an open mortgage. "EVEN IF YOU HAVE TO PAY =
1/4 PERCENT MORE INTEREST OR EVEN 1 and a 1/2 PERCENT MORE".=20
=20
IT IS BETTER TO PAY 16% DEDUCTIBLE THAN 11% NOT DEDUCTIBLE =
FOR MOST PEOPLE.=20
=20
IF YOUR MORTGAGE IS coming up for renewal in Dec, Jan, Feb =
or March (I will bet that 33% of outstanding mortgages will come due in =
the next nine months) then it is worthwhile for you to have another =
appraisal done and a new mortgage written at another institution where =
they will give you an open mortgage or at least one with better terms. I =
repeat, an open mortgage makes the system work better.=20
=20
Just to remind you. I am talking about making the interest =
deductible on the house that you already have. Instead of buying an IRA =
or an RRSP, buy a summer cabin, a ski cabin, a waterfront cabin or a =
sailboat, then use the cash flow the asset generates to make the =
interest deductible on your house.=20
=20
LET'S REARRANGE THE OLD FINANCES=20
=20
First, YOU must realize that all money coming into your =
pocket is YOURS to use first. YOU decide how you are going to dispose of =
this money. YOU decide whether the mortgage gets paid first (out of =
those funds) or whether the kids' teeth are fixed. When you are a =
self-employed proprietor, you realize this only too well.=20
=20
The ingredients for making your mortgage deductible are:=20
=20
1. An open mortgage=20
=20
2. A Creative and/or Understanding Banker=20
=20
3. An outside source of income where there are deductible =
expenses such as a rental house, rental condominium (even Hawaii), your =
own proprietorship business, or a stock trading or mutual fund account =
which is not registered.=20
=20
The method is simple. All the money that comes in from this =
outside source PLUS your regular mortgage payment gets paid off on the =
personal mortgage. At the same time, you have expenses, which have to be =
paid. The expenses, which includes mortgage interest, taxes, repairs and =
maintenance, agent's commissions, and other expenses of the rental =
units, all normal expenses of operating your own business, and the =
repurchase of stock if you are trading in stock. You see, we all realize =
that if we had sold off $100,000 of stock, paid off the mortgage and =
borrowed the money back to buy the stock, the interest would be =
deductible; but that is a big step. What we miss is that we can do this =
=93little steps=94 at a time.=20
=20
MUTUAL FUND PORTFOLIO=20
=20
For instance, if all you have is a mutual fund account with =
reinvested dividends, TAKE THE DIVIDENDS INTO YOUR OWN HANDS AND PAY =
DOWN THE MORTGAGE AND BORROW THE MONEY TO BUY =93ABOUT THE SAME=94 =
AMOUNT OF MUTUAL FUNDS THAT THE DIVIDENDS WOULD HAVE BOUGHT. This works, =
even if you borrowed the money to buy the mutual funds in the first =
place.=20
=20
PAYING OFF OUR PERSONAL MORTGAGE IS THE FIRST STEP TO =
FINANCIAL FREEDOM. If our `non-creative accountant' told us we should =
incorporate, before we had the mortgage and any other personal debt paid =
off, we have to put the corporation aside for a few months, until enough =
cash flow has been generated to pay off the mortgage.=20
=20
Here Is How This Works For The Third Time.=20
=20
You have an open mortgage (or credit card debts) at 15% for =
$50,000. In order to pay the $7,500 interest, you or someone in your =
family must earn $14,000, pay about $6,500 to have the $7,500 left over =
for the non-deductible interest payment. If you have a business grossing =
$5,000 per month, you take the $5,000 per month and apply it to the =
non-deductible mortgage. Then when you need money at the end of each and =
every month to pay creditors, you borrow it (using the new equity in =
your house as security for a secondary charge of some sort). i.e. You =
use borrowed money to pay the rent, pay the utilities, pay the wages, =
etc., by way of a floating chattel, or second charge.=20
=20
You will likely have to pay 1% or 2% more interest to do =
this. But now the 16% interest on the $50,000 debt is DEDUCTIBLE. This =
means that you or your business pays from $2,000 to $4,000 less tax this =
year and next year and next year and next year.=20
=20
I have seen situations where a business could reduce its =
GROSS by 54% and the owner would have more spending money because the =
interest is deductible.=20
=20
If you are trading stocks, every time you trade, take ALL =
the profit plus principal and apply it to your mortgage. When buying new =
stock, borrow money for the purchase so that the interest is deductible. =
Use dividends received to pay down the mortgage and use the increased =
equity in the house to finance more stock or mutuals.=20
=20
And do not tell me it is not worth it. Obviously, the =
self-employed person or heavy stock trader can manage this very quickly. =
=20
The following example shows how the owner of rental property =
can rearrange the deductibility of his interest payments quite quickly. =
I have assumed starting in January for simplicity's sake.=20
=20
EXAMPLE - Salaried employee earning $60,000 and in an =
effective 50% tax bracket (for easier calculation, depending on province =
or state, and city, it could be from 40% to 50%) buys two condominiums =
to rent out and applies the rent in a new and creative manner against =
the $50,000 mortgage at 15% on his house. (In year one - he starts off =
with $50,000, pays $8,000 in regular payments and applies $12,000 in =
gross rents from rentals to the mortgage.)=20
=20
Year ONE looks like this: $50,000 + 7,000 Interest - 8,000 =
Regular payment - 12,000 Extra payment =3D $37,000 O/S at 15% plus =
borrows $12,000 to make payments on Apartments, and has to pay 16% or =
$1,920 which is deductible =3D gets $960 tax refund. (For ease, I have =
assumed January to December calendar year.) Total borrowed about =
$49,000.=20
=20
Year TWO looks like this: $37,000 @ 15% + 5,000 interest - =
8,000 regular payment 12,000 extra payment =3D $22,000 O/S @ 15% plus =
borrows $12,000 more (total $24,000) @ 16% to MAKE APARTMENT payments, =
and has to pay a total of $3,840 which is deductible and gets back =
$1,920 as a tax deduction. Total borrowed approximately $46,000.=20
=20
By the end of 42 months, we owe about $42,000 at 16% and the =
interest is deductible (i.e., 16% of $42,000 =3D $6,720 with a $3,000 =
tax refund).=20
=20
WORTH DOING? -- OF COURSE!=20
=20
=20
david ingram=20
The CEN-TA Group provides US / Canada Income Tax Advice, =
Preparation and Assistance in obtaining US working visas under the Free =
Trade Agreement (NAFTA)=20
=20
=20
More information can be found at www.centa.com.=20
=20
Call us at (604) 913-9133=20
=20
Fax us at (604) 913-9123=20
=20
Or email me at [email protected] for more information =20
=20
=20
=20
=20
Copyright =A9 1996-2004 david Ingram
Updated February 23, 2004, All rights Reserved
Cross-border Income Tax Preparation Experts
NAFTA Consultation on Visas, Taxation, Immigration, Cross =
Border, Canada, USA, Mexico
=20
=20
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