by Polaris Tax Counsel | May 27, 2015 | Cross-Border Tax
The standard solution to the PFIC problem offered by certain banks and investment funds is that a US investor in a PFIC should rely on the QEF election. This is an election on behalf of the taxpayer that the products in which they have invested and to which the...
by Polaris Tax Counsel | Apr 16, 2015 | Cross-Border Tax
The Canadian mutual fund trust is a very common Canadian investment structure. It is used by retail mutual and exchange traded funds, REITs, income trusts, and other investment fund. A common view is that US taxpayers (whether they reside in the US or are US...
by Polaris Tax Counsel | Apr 16, 2015 | Cross-Border Tax
Of all the tax problems faced by a US citizen in Canada none are as potentially fraught as the ownership of Canadian mutual funds. A commonly held view is that these funds are Passive Foreign Investment Companies (PFICs) under US law. This view is based on an...
by Polaris Tax Counsel | Apr 16, 2015 | Cross-Border Tax
Canadian mutual funds held inside of an RRSP should not cause US tax problems. Assuming that Canadian mutual funds are PFICs (a position that’s far from certain), holding them in an RRSP negates the bad tax consequences that would otherwise come with stock in a PFIC...
by Polaris Tax Counsel | Apr 4, 2015 | Cross-Border Tax
If you’re a U.S. citizen living in Canada, you might be frantic about the IRS tax crackdown and hefty fines if you haven’t been tax compliant. How fast can the IRS come after you? What are its enforcement powers in Canada, anyway? Turns out, Canadian law has a trick...
