Is income tax higher in the US or Canada? - it DEPENDS -
My_question_is: Applicable to both US and
Canada
Subject: Income taxes... IRS or CRA?
Expert: [email protected]
Date: Friday March 23, 2007
Time: 06:12 PM -0500
QUESTION:
I'm a Canadian citizen living and working in Niagara Falls, ON. I married a US citizen in November and have applied for a K3 visa. If and when I move to Buffalo, NY to live with my wife (who won't relocate here), I'll still be working in Canada as I have a good job. Do I pay taxes as usual to CRA and do the AMT in the US or can I just pay the IRS..?? I can't receive health care, unemployment or pension from the Ontario government anymore if I live in New York, so I'd rather pay US taxes as they are lower.
Any help you can provide would be appreciated.
_____________________________________________________Subject: Income taxes... IRS or CRA?
Expert: [email protected]
Date: Friday March 23, 2007
Time: 06:12 PM -0500
QUESTION:
I'm a Canadian citizen living and working in Niagara Falls, ON. I married a US citizen in November and have applied for a K3 visa. If and when I move to Buffalo, NY to live with my wife (who won't relocate here), I'll still be working in Canada as I have a good job. Do I pay taxes as usual to CRA and do the AMT in the US or can I just pay the IRS..?? I can't receive health care, unemployment or pension from the Ontario government anymore if I live in New York, so I'd rather pay US taxes as they are lower.
Any help you can provide would be appreciated.
david ingram replies:
You will continue to pay Canada taxes just as if you lived in Canada.
Then you will report the income on your US return and file form 1116 to claim the credit for the Income tax, CPP and EI that you paid to CANADA.
The AMT does not apply anymore in your situation.
However, you are incorrect about New York having lower taxes.
If you were comparing Toronto and New York City, New York City is much higher.
Calculated as Married filing separately.
However I used $50,000 US as a Niagara falls New York salary and that works out to $2516.00 State tax, $6,951.00 Fed Tax, $3,100 FICA and $725.00 Medicare for a total of $13,292 US or $15,074.37 Cdn at 1.1340936
At the same exchange rate, $50,000 US is $56,704.68 which earns Ontario Tax of $4,044.59, Fed Tax of $8,231.00, CPP of $1,910.70 and EI of $729.70 for a total of $14,915.99 Canadian.
With the exception of mortgage interest as a deduction, the other deductions in the US are NOT AS GOOD as Canadian deductions and since I can (with a little time and reorganization) make a Canadian mortgage deductible as well (Nov 2001 Newsletter in top left hand box at www.centa.com), I do not take that into consideration.
________
The following answer goes even further
David,
________________________________________________________________
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.
.
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.
david ingram wrote:
Calls welcomed from 10 AM to 9 PM 7 days a week Vancouver (LA) time - (please do not fax or phone outside of those hours as this is a home office)
$1,600 would be for two people with income from two countries
David Ingram expert income tax help and preparation of US Canada Mexico non-resident and cross border returns with rental dividend wages self-employed and royalty foreign tax credits family estate trust trusts income tax convention treaty
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Disclaimer: This question has been answered without detailed
information or consultation and is to be regarded only as general
comment. Nothing in this message is or should be construed as advice
in any particular circumstances. No contract exists between the reader and the
author and any and all non-contractual duties are expressly denied. All
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Be ALERT, the world needs more
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David Ingram gives expert income
tax & immigration help to non-resident Americans & Canadians from
New York to California to Mexico family,
estate, income trust trusts Cross border, dual citizen - out of
country investments are all handled with competence &
authority.
Phone consultations are $400 for 15 minutes to 50
minutes (professional hour). Please note that GST is added if product remains in
Canada or a phone consultation is in Canada.
This is not intended to be definitive but in
general I am quoting $800 to $2,800 for a dual country tax return.
$800 would be one T4 slip one W2 slip one or two
interest slips and you lived in one country only - no self employment or rentals
or capital gains - you did not move into or out of the country in this
year.
$1,000 would be the same with one rental
$1,200 would be the same with one business no
rental
$1,200 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.
$1,500 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
$1,600 would be for two people with income from two countries
$2,800 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 $150.00 up.
With a Rental for $350
A Business for $350 - Rental and business likely
$450
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 $800 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.
Just a guideline not etched in
stone.
This from "ask an income trusts tax and immigration expert"
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