Canadian resident- How to buy a home in USA?

The treaty article which changed the way investments are valued when immigrating from Canada to US applies only to investments subject to deemed disposition rules. RRSPs, since they are tax sheltered in canada, ere not subject to deemed disposition, and thus it is still advisable to crystalize any gains in RRSP investments before entering US.

That's a useful bit of information because the IRS and the CRA gave me fluffy answers when I asked and they seemed to be saying what I posted, which is why I said contact them because they're the only definitive source. That's clearly something that needs to be changed in the treaty because it's stupid to be forced to crystalize gains in an RRSP when the treaty makes changes to treat RRSPs and departure tax more advantageously.

Article XXIII.7: "Where at any time an individual is treated for the purposes of taxation by a Contracting State as having alienated a property and is taxed in that State by reason thereof

Where at any time an individual is taxed by Canada for moving their tax home abroad. Sheesh.

-- Fri Aug 28, 2009 1:11 pm --

I am a canadian, in Arizona, taking advantage of the RE market. I use an LLC for every house, the LLC is owned by my canadian corp that I transferred to USA. I maintain both, which worries me for next years taxes.

Not clear on what your situation is here. You've immigrated your Canadian corporation? It may be subject to departure tax. Are you resident in the US or Canada? What is the income exactly to these corporations, are you renting out these properties or is it all capital gains? Are you paying out all the income?

Anyway, you claim a foreign tax credit for a corporation on schedule 21. Also depends on the structure of the corporations, whether you're using an S-corporation or a CCPC in Canada or whatever because the CCPC rate is lower than the US corporate tax rate. But essentially corporation taxes are based on profits, so if the holding corporation realizes a profit based on the operation of the corporations it owns there will be tax.

I would disagree that contacting CRA and especially IRS is of any value in any instance.

IRS telephlunkies are notorious for giving different answers to the same question.

And remember, deemed disposition is not a result of moving the asset abroad, it is a result of moving oneself abroad.

Yeah I just realized that and corrected it just as you posted.

I'm not talking about the telephone help people, I actually wrote them a letter and spoke to the guy on the phone who replied to it.

Letter, phone... makes no difference. Low level swizzle servant.

How Difficult will it be for a US citizen living in canada to get a US mortgage???

Well your credit history will be Canadian, that will be the main stumbling block I suspect. Best idea is to phone Bank of America as they seem to be the ones who are most keen on issuing Canadians mortgages.

The one advantage a USC will have will be the ability to present the loan officer with past/current 1040's, which is something they will be able to understand.

Hello!

I am a Canadian that will be moving to Boston to work on a visa. I was interested in purchasing a home but am not sure on the logistics for a Canadian to buy a home in the USA, as I would not have any previous credit history in the USA. I do have a job contract though for my new job.

Can anybody give me some advice? How would a Canadian go about getting a mortgage in the USA?

You need to go IN PERSON to a bank. You can't get an automated internet mortgage, becuse your credit history is not yet established.

You also need a hefty downpayment.

Is it possible to obtain financing from a Canadian lender to purchase a US home.?
Are lending requirements more sticky with US lenders.?