tax for CDN resident, US citizen -



QUESTION:
Hi, I was born in the US but live and work in Canada with only Cdn income. I am trying to do my US tax form and this year is the first year that the US tax appears higher than Cdn. I am single have about 35K in earned income and 25K in dividends and capital gains from stocks and mutual funds. Does the 50% Cap Gain inclusion rate in Canada really make the tax lower here now? If I really do owe tax to the US do I refile my Cdn tax form with the tax paid to the US as a foreign tax credit? The Foreign Income Tax Worksheet seems to cause the Capital Gains and Dividends to be taxed by the US at the highest marginal rate vs a low rate here. Am I missing something important? Thanks.

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david ingram replies:

Because of the different treatment of capital gains and dividends, it is not unusual for you to owe tax to the US on top of the tax to Canada.  For many things, the tax rate is indeed lower in Canada.   The Canadian Dividend Tax credit.

The tax paid to the US is not eligible for a foreign tax credit in Canada unless they were US mutual funds which is another story. then you would be paying the US 15% tax first on any dividends and claiming a foreign tax credit in Canada.

If the calculated tax to the US worked out to more than 15%, you would claim the excess back on your US return by using form 1116 and checking off the "resourced by treaty" box under Article 24 (5)(c) of the Treaty. 

For the record, I have only seen this article dealt with correctly two times by other accountants.  Once was by Steve Peters, a CPA  in Halifax and the other by a CPA with the name of Lentz.

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This shows you the differences that can arise.
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QUESTION:

Hello,
My wife and I (both US citizens) are considering moving to 
Vancouver.  I'm a xxxxxxxx, telecommuting for a start-up company (Delaware company with 
its office in New York City).  And I'm trying to start a new career as a screenwriter/cameraman/director.

I'm trying to make a general comparison of the taxes we'd 
pay as residents of Seattle, or Portland, OR, or Vancouver.  
We believe Vancouver would be the best fit, but we're 
concerned about Canadian taxes.

Current salary through the company is $62,500 (US).  
Other interest income from U.S. accounts totals about 
$23,000 per year (US).

Can you give me a basic summary of what I might expect 
as U.S. versus Canadian (federal/provincial/city) taxes to 
expect?

Also, if the start-up is successful, it may mean a buy-out 
in two or more years.  Through annual stock options, my 
portion could mean value of seven figures.  Any obvious 
considerations in that regard.

Great website! I'm subscribing to the newsletter, and have 
no doubt where I'm coming for my tax help if we end up 
in Vancouver.

Thanks very much,

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david ingram replies:

It is tax season and I am too busy to do this what-if.  Maybe if you send it back in July, it might get into the free list.

in the meantime, this older question might help.  BC has slightly lower taxes than Ontario.

Washington State has no State income tax and is generally lower than BC.

Oregon has a state income tax and but no state sales tax.  Washington and Oregon both cheaper overall tax than Michigan.


On my opinion, the career of screenwriter cameraman director is a tough one in Vancouver at the moment.  Vancouver has a lot of those people out of work at the moment because of the 40% drop in the value of the US dollar.
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My_question_is: Applicable to both US and Canada
Subject:        US citizen working in Canada; what are my tax liabilities?
Expert:         taxman@centa.com
Date:           Friday January 04, 2008
Time:           12:54 AM -0000

QUESTION:

I am planning to start working for a canadian company in toronto, ontario on Feburary 1st, 2008. I have a wife and 4 kids whose ages at the end of 2008 will be 18, 16,14 and 3. My wife is a homemaker and the children will provide no additional income. My estimated gross will be 195,000 with rental costs of approx. 30,000. My questions are the following: What is my estimated provincial and federal tax liabilities and what credits am I eligible for? I will also be maintaining a residence in knoxville, tn USA and will be reporting the month of January's income earned in the USA. Next Question is what are my liabilites/credits for the income earned in Ontario,CA? Thanks for your assistance in this matter.


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david ingram replies:

You really require someone to do the calculations for you and your family.

We would charge in the $400 range to do that for you.

In he meantime, the following which I did answer in November might give you an idea.

In your case, because all the income is in your name, tax will be significantly higher in Canada because you will be paying on one income and you will be paying Ontario Tax while coming from essentially tax free Tennessee

On the other hand, medical insurance will be significantly lower.


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David,
 
I am a U.S. citizen and resident, married to a (non-working) dual U.S.-Canadian citizen. I recently learned that the company where I've worked for the last 20+ years is closing its doors near the end of this year. I'm 55 and can't get my pension for at least 5 years...10 years if I want a full pension. We've been thinking of the idea of moving across the border to Canada (wife would sponser me), and I have a question. Would it make any sense tax-wise for me to live and work in Canada, pay into CPP for 5 or 10 years? I understand that Canadian taxes are higher than in Michigan, and I have mutual funds and other savings that are generating about $10,000 in yearly interest/dividends/capital gains that I would be leaving in the U.S.
 
Thanks,
 
________________________________________________________________
david ingram replies:

As an esoteric exercise, I decided to see what the difference actually was because Canadian taxes are NOT always higher than the US, particularly where two spouses have equal earnings. 

The big difference is that the US has a joint tax return rate and when one spouse works an the other does not, a discrepancy does arise.

I used a US salary of $60,000 and a joint 1040 and MI 1040.

I did not use any deductions other than the standard deduction and did not claim for any children.

The results were

US fed tax of    5.714
MI tax of          2,083
FICA                3,720
Medicare             870           
For a total of   12,387      which converts to $14,048.02 in Canadian funds
If you had lived in Detroit, the city tax would be $1,470 changing the figures to
a total of  $13,857.00 US or $15,715.14 Canadian

I converted the $60,000 to $68,045.62 Canadian

The results were
Cdn Fed tax of   9,581.69
ON tax of          4,659.14
CPP of              1,910.70
EI of                    729.30
for a total of     16,880.83 which converts to $14,884.86 in US funds

The difference is $2,497.86 or about $200 a month. if you did not move from a Michigan city with a tax return or a difference of (14,884.86 - 13,857) $1,027.86 if you moved from Detroit

Then - (I was intrigued) I tried it with you both receiving $30,000 US


The results were

US fed tax of    5.714
MI tax of          2,083
FICA                3,720
Medicare             870           
For a total of   12,387      which converts to $14,048.02 in Canadian funds
and $1,470 Detroit tax 'IF'  There is no change

Then I decided to show what would happen to a couple who moved to Canada and both worked equally.

I converted the $60,000 to $68,045.62 Canadian but split it into 2 returns of $34,022.81

The results were
Cdn Fed tax of   3,474.97 x's 2 or   6,949.94
ON tax of          1,721.67  x's 2 or  3,443.34
CPP of              1,510.88 x's 2  or  3,021.76
EI of                    636.23 x's 2 or   1,272 .45
for a total of     14,687.49 which converts to $12,950.86 in US funds


and is only a difference of  12,950.86 - 12,387 or  $563.86  or less than $50.00 a month AND  qualifies your wife for her own CPP.

Of course, if you moved from Detroit to Windsor, you would be paying ($13,857 - 12,950.86)  $906.14 LESS living in Canada.

For the record, I would normally charge a minimum of $400 Cdn for this 'what if' calculation and your question was rejected originally along with another 100 or so.  However, it caught my eye and I decided to use it as a major answer. 

The investment part of your income will also cause some differences because Canada will tax the dividends and capital gains differently, likely a little more.  However, if you switched your accounts to Canadian securities, the tax may be a little less because of Canada's dividend tax credit.

Hope this helps a bit.

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SUGGESTED PRICE GUIDELINES - May 17, 2008

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Phone consultations are $450 for 15 minutes to 50 minutes (professional hour). Please note that GST is added if product remains in Canada or is to be returned to Canada or a phone consultation is in Canada. ($472.50 with GST for in person or if you are on the telephone in Canada) expert  US Canada Canadian American  Mexican Income Tax  service and help.
This is not intended to be definitive but in general I am quoting $900 to $3,000 for a dual country tax return.

$900 would be one T4 slip one W2 slip one or two interest slips and you lived in one country only (but were filing both countries) - no self employment or rentals or capital gains - you did not move into or out of the country in this year.
 
$1,200 would be the same with one rental
 
$1,300 would be the same with one business no rental
 
$1,300 would be the minimum with a move in or out of the country. These are complicated because of the back and forth foreign tax credits. - The IRS says a foreign tax credit takes 1 hour and 53 minutes.
 
$1,600 would be the minimum with a rental or two in the country you do not live in or a rental and a business and foreign tax credits  no move in or out

$1,700 would be for two people with income from two countries

$3,000 would be all of the above and you moved in and out of the country.
 
This is just a guideline for US / Canadian returns
 
We will still prepare Canadian only (lives in Canada, no US connection period) with two or three slips and no capital gains, etc. for $200.00 up. However, if you have a stack of 1099, or T3 or T4A or T5 or K1 reporting forms, expect to pay an average of $10.00 each with up to $50.00 for a K1 or T5013 or T5008 or T101 --- Income trusts with amounts in box 42 are an even larger problem and will be more expensive. - i.e. 20 information slips will be at least $350.00
 
With a Rental for $400, two or three rentals for $550 to $700 (i.e. $150 per rental) First year Rental - plus $250.
 
A Business for $400 - Rental and business likely $550 to $700
 
And an American only (lives in the US with no Canadian income or filing period) with about the same things in the same range with a little bit more if there is a state return.
 
Moving in or out of the country or part year earnings in the US will ALWAYS be $900 and up.
 
TDF 90-22.1 forms are $50 for the first and $25.00 each after that when part of a tax return.
 
8891 forms are generally $50.00 to $100.00 each.
 
18 RRSPs would be $900.00 - (maybe amalgamate a couple)
 
Capital gains *sales)  are likely $50.00 for the first and $20.00 each after that.

Catch - up returns for the US where we use the Canadian return as a guide for seven years at a time will be from $150 to $600.00 per year depending upon numbers of bank accounts, RRSP's, existence of rental houses, self employment, etc. Note that these returns tend to be informational rather than taxable.  In fact, if there are children involved, we usually get refunds of $1,000 per child per year for 3 years.  We have done several catch-ups where the client has received as much as $6,000 back for an $1,800 bill and one recently with 6 children is resulting in over $12,000 refund. 

Email and Faxed information is convenient for the sender but very time consuming and hard to keep track of when they come in multiple files.  As of May 1, 2008, we will charge or be charging a surcharge for information that comes in more than two files.  It can take us a valuable hour or more  to try and put together the file when someone sends 10 emails or 15 attachments, etc. We had one return with over 50 faxes and emails for instance. 

This is a guideline not etched in stone.  If you do your own TDF-90 forms, it is to your advantage. However, if we put them in the first year, the computer carries them forward beautifully.
 







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