QUESTION: My home-based software consulting business will be earning over $180K this year. I haven't kept any employees, and divide the current income between myself and my spouse on a partnership basis. We currently live in XXXXXXXXXX, BC and plan to move to XXXXXXXX, AB sometime this year when we sell our house. I know that you don't like incorporations, but at my newly achieved income level, I am guessing that it's advisable to incorporate. Do you have any recommendations for good tax advisors/accountants/estate planners/lawyers in XXXXXXXX whom I can get in touch with? If you could advise me instead of recommending someone else then will it be a problem to deal with you in case I am in Alberta, and you are here in North Van? We do own a rental property in the US, and file 1040NR every year. We have 2 daughters - one of them is a US citizen. The rest of us are Indian Citizens who are permanent residents in Canada for last 4 years, and are waiting for our Canadian citizenship. So, our taxes/business and estate will span 3 countries (US, Canada, and India). Currently, my business is only limited to BC, so even if I move to Alberta, my clients will still be in BC, so I need advice on across-province tax advise. Thanks, in advance. XXXXXXX.---------------------------------------------------------------
david ingram replies:
Before you incorporate, make sure that your house mortgage is deductible. If it is not, don't incorporate.
I am quite happy to deal with you in Alberta or BC. Half of our clients do not even live in Canada.
I have no recommendations in Calgary or Edmonton or Red Deer..
There must be someone but they have not come across my desk. There are a couple who are really bad.
No, I will not name them because I do not need to get involved in a libel suit and have better things to do.
I do not see why you would move to Alberta if your clients are in BC. any perceived tax savings is not worth the move in my opinion. If your intention is to keep your clients in BC and develop a new market by being there, that is a different matter.
And if you desire to deal with someone else other than our operation, it is not that I do not name any others.
The following former answer mentions some tax differences and lists people who are more than qualified to help you out
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QUESTION: I am an American who married a Canadian. I was granted residency in Canada in Nov. 2007. I took my financial papers to an accountant, as I knew there would be some problems. He is now telling me that in addition to the $12,000+ that I have already paid in the US, that I must pay $9,000 in Canada. He said I might get a $1.000 refund from the US. This feels like double taxation!
I maintained an apartment in the States until the end of 2007, but spent most of my time in Canada. I have been told that this means that I must pay Canadian tax for the entire year for services I received. I did not go on BC medical until this month. Help! --------------------------------------------------------------------------- david ingram replies:
It is certainly possible that you owe more if you moved from a no-tax state like Nevada, Washington, Alaska, Texas or Florida.
It would be unlikely if you moved from a high tax state like California or New York.
In a recent situation where a client did the same thing from Nevada to Vancouver, his tax was $4,000 higher in Vancouver but was still lower than if he had moved to California or New York city.
Ideally, you would have the same person do both returns. If you do not want to deal with us, I recommend several others at the end of this older Q & A which will give you some idea of how it works. In the meantime, you should read the October 1995 newsletter in the top left hand box at www.centa.com and the US Canada Taxation section in the second box down on the right had side at www.centa.com
.
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, ---------------------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.
------------------------------------------
My_question_is: Applicable to both US and
Canada
Subject: US citizen working in Canada; what are my tax liabilities?
Expert: [email protected]
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 February 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 liabilities/credits for the income earned in Ontario,CA? Thanks for your assistance in this matter.
-----------------------------------------------------------------------------------------------------Subject: US citizen working in Canada; what are my tax liabilities?
Expert: [email protected]
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 February 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 liabilities/credits for the income earned in Ontario,CA? Thanks for your assistance in this matter.
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.
--------------------------------------------------------------------
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 sponsor 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.
------------------------
The following people are skilled at US Canadian tax returns
Some hints to get them done. Who could look after you?
Gary Gauvin is absolutely qualified to deal with you. He is an old business partner of mine from Ottawa. He now practices outside of Dallas Texas as a one or 1 1/2 person office. If you deal with Gary, you will deal with Gary. He is a US enrolled agent. You can find his website easily. Type - income Tax Expert - into
google. Gary will come up as number one or two. Why, because he is. If I am looking for a first or second opinion, I call Gary. Disadvantage -
Gary is a one and a half person office. Advantage - You will always get to talk to Gary.
Gary likes corporations. I and my four associates do not like them. I like dealing with individuals who deal cross-border withOUT corporations.
OR KPMG in Vancouver. The last time I checked they had 22 people in their US/Canada department. call (604) 691-3025. Advantage - Lots of Backup. Disadvantage - It will be hard to get the same person to deal with you three times in a row.
OR Steve Peters with KPMG in Halifax (902) 492-6011
OR Kevin Nightingale in Toronto (416) 733-9595
OR Len Vandenberg with BDO Dunwoody in Kelowna, BC. (250) 763-7600
OR Steve Katz in Vancouver at (604) 732-1515
OR Brad Howland in Victoria at (250) 598-6258
Whoever you choose, you would likely do well to consult with me for one or two hours a year. If I have a suggestion, it will be worth it. If I can't come up with anything, you will know that what you are doing is likely the best track. I will compare it to my dentist. When I went in the fall of 2005, I ended up with $16,000 to $18,000 of dental bills, a root canal, a bunch of pain, and a lot of nice new caps, etc.
When I went for an inspection on Jan 29th, he could not find anything wrong except that I was not flossing. Which one did i appreciate more?
Well both - the first time was expensive but dealt with years of neglect. The second said I am on the right track.
Good luck.
Looking at the California Non-resident Adjustment Form CA(NR) will give you an idea of how this leaving the country stuff works. http://www.ftb.ca.gov/forms/07_forms/07_540nrca.pdf
------------------------
SUGGESTED PRICE GUIDELINES - May 17,
2008
david ingram's US / Canada Services
US / Canada / Mexico tax, Immigration and working Visa Specialists
US / Canada Real Estate Specialists
My Home office is at:
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) expert US Canada Canadian American Mexican Income Tax service help.
$1,700 would be for two people with income from two countries
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.
david ingram's US / Canada Services
US / Canada / Mexico tax, Immigration and working Visa Specialists
US / Canada Real Estate Specialists
My Home office is at:
4466 Prospect Road
North Vancouver, BC, CANADA, V7N 3L7
Cell (604) 657-8451 -
(604) 980-0321 Fax (604) 980-0325
North Vancouver, BC, CANADA, V7N 3L7
Cell (604) 657-8451 -
(604) 980-0321 Fax (604) 980-0325
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) expert US Canada Canadian American Mexican Income Tax service help.
pert US Canada Canadian American
Mexican Income Tax service and
help.
David Ingram gives expert income
tax service & 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 $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.