The IRS has made the following announcement:
Revenue Procedure 2010-19 provides guidance for individuals who emigrate from Canada and wish to make an election for U.S. federal income tax purposes under paragraph 7 of Article XIII (Gains) of the Convention between the United States of America and Canada with Respect to Taxes on Income and on Capital, signed on September 26, 1980, as amended by Protocols signed on June 14, 1983, March 28, 1984, March 17, 1995, July 29, 1997, and September 21, 2007 (the "Treaty") with respect to property that is subject to Canadian departure tax under Canada's deemed alienation rules (the terms "alienation" and "disposition" are used interchangeably throughout this revenue procedure). This guidance is limited to the circumstances described in the revenue procedure and therefore does not address other situations in which the election under paragraph 7 of Article XIII may be available.
Revenue Procedure 2010-19 will be in IRB 2010-13, dated March 29, 2010.
Posted by Joshua Hock, Associate Editor, Wealth Strategies Journal
Leave a comment