<?xml version="1.0" encoding="UTF-8"?>        <rss version="2.0"
             xmlns:atom="http://www.w3.org/2005/Atom"
             xmlns:dc="http://purl.org/dc/elements/1.1/"
             xmlns:sy="http://purl.org/rss/1.0/modules/syndication/"
             xmlns:admin="http://webns.net/mvcb/"
             xmlns:rdf="http://www.w3.org/1999/02/22-rdf-syntax-ns#"
             xmlns:content="http://purl.org/rss/1.0/modules/content/">
        <channel>
            <title>
									Madan CPA Forum - Recent Posts				            </title>
            <link>https://madancpa.beautybrandbuilders.co/learn/</link>
            <description>Madan CPA Discussion Board</description>
            <language>en-US</language>
            <lastBuildDate>Sat, 06 Jun 2026 00:25:12 +0000</lastBuildDate>
            <generator>wpForo</generator>
            <ttl>60</ttl>
							                    <item>
                        <title>Answer: Request for Advice Regarding CPP Survivor Pension and Tax Refund</title>
                        <link>https://madancpa.beautybrandbuilders.co/learn/canadiantaxforum/request-for-advice-regarding-cpp-survivor-pension-and-tax-refund/#post-1389</link>
                        <pubDate>Tue, 26 May 2026 19:25:59 +0000</pubDate>
                        <description><![CDATA[Hi Marie,

Thank you for your message.

Yes, we can assist you with this matter. Based on the facts you provided, you are a non-resident of Canada living in the Philippines and your Cana...]]></description>
                        <content:encoded><![CDATA[Hi Marie,

Thank you for your message.

Yes, we can assist you with this matter. Based on the facts you provided, you are a non-resident of Canada living in the Philippines and your Canadian income is limited to a CPP Survivor’s Pension.

For non-residents, CPP and other Canadian pension payments are generally subject to 25% non-resident withholding tax, unless reduced by treaty or by CRA approval, such as through an approved NR5 application. CRA also allows certain non-residents receiving Canadian pension income to file a Section 217 return, which may result in a refund of some or all of the tax withheld, depending on the final calculation. 

<strong>1. Can you still file a 2024 Section 217 return?</strong>

Yes, it may still be possible to file a 2024 Section 217 return, even if it is late. CRA may still process the return, but we would need to review your documents before confirming the best filing position.

<strong>2. Could you qualify for a refund?</strong>

Possibly, yes. Since your income is low and the 25% tax was withheld at source, a Section 217 return may allow you to recover part or all of the tax withheld. The refund amount would depend on your total worldwide income, the CPP amount received, and the tax calculation.

<strong>3. Why is 25% still being withheld even though the NR5 was approved at 0%?</strong>

This may be an administrative issue. The NR5 approval may not yet have been properly applied by Service Canada, or the payer may not have updated its withholding instructions. NR5 approvals are used to reduce non-resident withholding, and approved NR5 relief can generally cover multiple years.

You should contact Service Canada / CPP International Operations and provide them with a copy of the NR5 approval letter showing the approved 0% withholding rate.

<strong>4. Recommended next steps</strong>

Please send us the following documents for review:

<ol>
	<li>Your 2024 NR4 slip for the CPP Survivor’s Pension</li>

	<li>Your 2025 CPP payment details and withholding details</li>

	<li>The CRA NR5 approval letter showing the 0% withholding rate</li>

	<li>Any letters received from CRA or Service Canada</li>

	<li>Details of your worldwide income for 2024 and 2025, even if the income was nil or very low</li>

	<li>Your Philippine tax residency details and mailing address</ol></li>

Our fee to prepare a Section 217 non-resident tax return is $350 per year, plus disbursements. If CRA follow-up is required regarding the NR5 withholding issue, that would be billed separately at $140 per hour.

Regards,]]></content:encoded>
						                            <category domain="https://madancpa.beautybrandbuilders.co/learn/"></category>                        <dc:creator>MadanCA Team</dc:creator>
                        <guid isPermaLink="true">https://madancpa.beautybrandbuilders.co/learn/canadiantaxforum/request-for-advice-regarding-cpp-survivor-pension-and-tax-refund/#post-1389</guid>
                    </item>
				                    <item>
                        <title>Answer: Prorated Small Business Deduction (SBD) in short taxation year + CCPC status change</title>
                        <link>https://madancpa.beautybrandbuilders.co/learn/canadiantaxforum/prorated-small-business-deduction-sbd-in-short-taxation-year-ccpc-status-change/#post-1388</link>
                        <pubDate>Tue, 26 May 2026 19:17:26 +0000</pubDate>
                        <description><![CDATA[Hi,

Thank you for your question.

Based on the facts provided, the Small Business Deduction should apply only for the period during which the corporation was a CCPC.

Since the corpor...]]></description>
                        <content:encoded><![CDATA[Hi,

Thank you for your question.

Based on the facts provided, the Small Business Deduction should apply only for the period during which the corporation was a CCPC.

Since the corporation became a non-CCPC effective July 1, 2025, the corporation is generally deemed to have a taxation year-end immediately before that change, being June 30, 2025. This means the relevant CCPC taxation year would be March 1, 2025 to June 30, 2025.

The SBD business limit should therefore be prorated based on the number of days in that CCPC taxation year, not the full March 1 to December 31, 2025 period.

For example:

<strong>$500,000 × 122 days / 365 = approximately $167,123</strong>

Accordingly, the corporation would generally be eligible to claim the SBD only on qualifying active business income earned during the CCPC taxation year from March 1, 2025 to June 30, 2025, subject to the usual SBD limitations, including associated corporation rules, taxable capital grind, passive investment income grind, and other restrictions.

The corporation would generally not be eligible for the SBD for the period from July 1, 2025 to December 31, 2025, because it was no longer a CCPC during that period.

In short, the SBD does not apply for the entire March 1 to December 31 short year. It should be limited to the deemed short taxation year ending immediately before the corporation ceased to be a CCPC.

We recommend reviewing the ownership/control change documents and the timing of the income earned to ensure the T2 return is prepared correctly.

If you would like specific tax advice, you can book a 30-minute paid consultation with Allan Madan, CPA, CA here:
https://calendly.com/allanmadancpa

Kind regards,]]></content:encoded>
						                            <category domain="https://madancpa.beautybrandbuilders.co/learn/"></category>                        <dc:creator>MadanCA Team</dc:creator>
                        <guid isPermaLink="true">https://madancpa.beautybrandbuilders.co/learn/canadiantaxforum/prorated-small-business-deduction-sbd-in-short-taxation-year-ccpc-status-change/#post-1388</guid>
                    </item>
				                    <item>
                        <title>Prorated Small Business Deduction (SBD) in short taxation year + CCPC status change</title>
                        <link>https://madancpa.beautybrandbuilders.co/learn/canadiantaxforum/prorated-small-business-deduction-sbd-in-short-taxation-year-ccpc-status-change/#post-725</link>
                        <pubDate>Tue, 26 May 2026 04:20:35 +0000</pubDate>
                        <description><![CDATA[My corporation previously had a fiscal year from March to February. CRA has approved a change to a calendar year-end, so we will have a short taxation year from March 1, 2025 to December 31,...]]></description>
                        <content:encoded><![CDATA[My corporation previously had a fiscal year from March to February. CRA has approved a change to a calendar year-end, so we will have a short taxation year from March 1, 2025 to December 31, 2025, and thereafter future years will be January–December.
However, my corporation also became a non-CCPC effective July 1, 2025.

I am trying to understand how the small business deduction (SBD) limit is prorated in this situation.
Specifically:
Is the SBD limit for the short year (Mar 1 – Dec 31, 2025) prorated based on the full short taxation year length (March to December)?
Or is it effectively only prorated for the period the corporation was a CCPC (i.e., March 1 – June 30, 2025, when it was still CCPC), since after July 1 it became a non-CCPC?
In other words, does the SBD apply only up to the date CCPC status ends, or for the entire short taxation year?

Thank you for your guidance]]></content:encoded>
						                            <category domain="https://madancpa.beautybrandbuilders.co/learn/"></category>                        <dc:creator>Anonymous</dc:creator>
                        <guid isPermaLink="true">https://madancpa.beautybrandbuilders.co/learn/canadiantaxforum/prorated-small-business-deduction-sbd-in-short-taxation-year-ccpc-status-change/#post-725</guid>
                    </item>
				                    <item>
                        <title>Request for Advice Regarding CPP Survivor Pension and Tax Refund</title>
                        <link>https://madancpa.beautybrandbuilders.co/learn/canadiantaxforum/request-for-advice-regarding-cpp-survivor-pension-and-tax-refund/#post-724</link>
                        <pubDate>Sat, 23 May 2026 10:52:26 +0000</pubDate>
                        <description><![CDATA[Hello Sir,

I hope you are doing well. I would like to ask for professional advice regarding my situation as a non-resident receiving a CPP Survivor’s Pension from Canada.

I am a Filipi...]]></description>
                        <content:encoded><![CDATA[Hello Sir,

I hope you are doing well. I would like to ask for professional advice regarding my situation as a non-resident receiving a CPP Survivor’s Pension from Canada.

I am a Filipino resident and have never been to Canada. I am also a widow, and currently my only source of income is my CPP Survivor’s Pension. At the moment, I do not have a stable job and mainly rely on this pension for support.

I started receiving the pension in 2024. In 2025, I applied for an NR5 application and later received correspondence stating that it was approved with a 0% withholding tax rate. However, until now, 25% tax is still being withheld from my monthly pension payments.

I would also like to ask about filing under Section 217. Since I only started receiving the pension in 2024, I am wondering if it is still possible to file a 2024 Section 217 return even if it may already be considered late.

Because the 25% tax was withheld at source from my pension, I would like to know if I may still qualify for a tax refund, especially considering my low income and non-resident status.

I would sincerely appreciate your advice regarding:

- Whether I can still file a Section 217 return for 2024
- Whether I may qualify for a refund of the taxes withheld
- Why the approved 0% NR5 rate may not yet be reflected on my pension payments
- What steps I should take moving forward

Thank you very much for your time and assistance. I truly appreciate any guidance you can provide.

Sincerely,
Marie]]></content:encoded>
						                            <category domain="https://madancpa.beautybrandbuilders.co/learn/"></category>                        <dc:creator>Anonymous</dc:creator>
                        <guid isPermaLink="true">https://madancpa.beautybrandbuilders.co/learn/canadiantaxforum/request-for-advice-regarding-cpp-survivor-pension-and-tax-refund/#post-724</guid>
                    </item>
				                    <item>
                        <title>Answer: High-Tax Exclusion for Canadian Corporation Income</title>
                        <link>https://madancpa.beautybrandbuilders.co/learn/canadiantaxforum/high-tax-exclusion-for-canadian-corporation-income/#post-1387</link>
                        <pubDate>Fri, 22 May 2026 19:11:27 +0000</pubDate>
                        <description><![CDATA[Hello Anonymous, 

This is a very good question, because a Canadian corporation owned by U.S. residents can trigger U.S. controlled foreign corporation (“CFC”) reporting, including Form 54...]]></description>
                        <content:encoded><![CDATA[Hello Anonymous, 

This is a very good question, because a Canadian corporation owned by U.S. residents can trigger U.S. controlled foreign corporation (“CFC”) reporting, including Form 5471, Subpart F, and GILTI considerations.

In general, passive investment income earned by a CFC, such as interest income from GICs, may fall under the U.S. Subpart F rules as foreign personal holding company income. Separately, income that is not included under Subpart F may need to be reviewed under the GILTI rules.

The high-tax exception / high-tax exclusion may apply where the relevant income is subject to foreign tax at an effective rate greater than 90% of the U.S. corporate tax rate. Since the current U.S. corporate tax rate is 21%, the commonly referenced threshold is 18.9%.

Therefore, if the Canadian corporation is paying Canadian corporate tax at an effective rate of approximately 50% on the GIC interest income, that income may generally be a candidate for the high-tax exception or high-tax exclusion. In many cases, the high Canadian tax rate can reduce or eliminate the current U.S. inclusion under Subpart F or GILTI.

However, this is not automatic. Several technical points must be reviewed:

<ol>
	<li>Whether the corporation is a CFC for U.S. tax purposes;</li>

	<li>Whether the GIC interest is classified as Subpart F income, GILTI tested income, or excluded income;</li>

	<li>Whether the Canadian tax paid is properly attributable to that specific item or tested unit of income;</li>

	<li>Whether the high-tax election is properly made on the U.S. return;</li>
	<li>Whether there are multiple tested units, multiple income categories, losses, deductions, or timing differences that affect the effective tax rate calculation;</li>

	<li>Whether the U.S. shareholders are individuals or corporations, since this can affect the overall U.S. tax result and foreign tax credit treatment.</li>
</ol>

For a simple Canadian corporation earning only GIC interest and paying Canadian tax at approximately 50%, the high-tax rules may be helpful. However, the result should be confirmed through a proper Form 5471 analysis, including Schedule I, Schedule I-1, Schedule E, Schedule J, Schedule P, and the applicable Subpart F / GILTI calculations.

You should not assume that the Canadian tax rate alone automatically eliminates the U.S. reporting or income inclusion. Form 5471 may still be required even where the high-tax exception or high-tax exclusion reduces the U.S. taxable inclusion to nil.

Given the penalties associated with incomplete or incorrect Form 5471 filings, I recommend having a cross-border tax professional review the corporation’s financial statements, Canadian corporate tax return, ownership structure, and prior U.S. filings before taking a position.]]></content:encoded>
						                            <category domain="https://madancpa.beautybrandbuilders.co/learn/"></category>                        <dc:creator>MadanCA Team</dc:creator>
                        <guid isPermaLink="true">https://madancpa.beautybrandbuilders.co/learn/canadiantaxforum/high-tax-exclusion-for-canadian-corporation-income/#post-1387</guid>
                    </item>
				                    <item>
                        <title>High-Tax Exclusion for Canadian Corporation Income</title>
                        <link>https://madancpa.beautybrandbuilders.co/learn/canadiantaxforum/high-tax-exclusion-for-canadian-corporation-income/#post-723</link>
                        <pubDate>Wed, 20 May 2026 20:13:56 +0000</pubDate>
                        <description><![CDATA[I have a question regarding U.S. Form 5471 and the GILTI/subpart high-tax exclusion.

If a Canadian corporation(non-ccpc with 100% share holders are US residents) is earning investment inc...]]></description>
                        <content:encoded><![CDATA[I have a question regarding U.S. Form 5471 and the GILTI/subpart high-tax exclusion.

If a Canadian corporation(non-ccpc with 100% share holders are US residents) is earning investment income (e.g., GIC interest ~20K per year) and is already being taxed in Canada at an effective rate of roughly ~50%, would that income generally qualify for the U.S. high-tax exclusion (&gt;18.9% effective tax rate)?

In other words, can the high Canadian corporate tax rate effectively eliminate the GILTI/subpart inclusion for that income under the tested unit rules, or are there situations where it would still be included?]]></content:encoded>
						                            <category domain="https://madancpa.beautybrandbuilders.co/learn/"></category>                        <dc:creator>Anonymous</dc:creator>
                        <guid isPermaLink="true">https://madancpa.beautybrandbuilders.co/learn/canadiantaxforum/high-tax-exclusion-for-canadian-corporation-income/#post-723</guid>
                    </item>
				                    <item>
                        <title>Answer: I have nothing in canada except for my canadian bank acct. Living in the US presently, how can i declare as non resident of canada</title>
                        <link>https://madancpa.beautybrandbuilders.co/learn/canadiantaxforum/i-have-nothing-in-canada-except-for-my-canadian-bank-acct-living-in-the-us-presently-how-can-i-declare-as-non-resident-of-canada/#post-1386</link>
                        <pubDate>Fri, 08 May 2026 21:44:19 +0000</pubDate>
                        <description><![CDATA[Hi Julie,

Thank you for contacting me.

Based on what you described, I can assist you with determining your Canadian non-resident status and the related Canadian tax filing requirements...]]></description>
                        <content:encoded><![CDATA[Hi Julie,

Thank you for contacting me.

Based on what you described, I can assist you with determining your Canadian non-resident status and the related Canadian tax filing requirements. Since you are a Canadian citizen, a U.S. green card holder, and currently living in the U.S. with limited Canadian ties, I would need to review your facts carefully, including:

	
<ol>
	<li>The date you moved to the U.S.</li>

	<li>Whether you own or rent any property in Canada</li>

	<li>Whether you have a spouse or dependants in Canada</li>

	<li>Whether you still have Canadian health coverage, driver’s licence, memberships, investments, RRSP/RRIF, TFSA, or other accounts</li>

	<li>Whether you have filed Canadian tax returns since moving to the U.S.</li>

	<li>Whether you are already receiving CPP or OAS</ol></li>

In general, non-residents of Canada can receive CPP and OAS, provided they meet the eligibility requirements. However, Canadian withholding tax may apply, and the income must also be considered for U.S. tax reporting purposes.

To provide proper advice, please book a 30-minute paid consultation with me for $140 + HST using this link:

https://calendly.com/allanmadancpa

If you would like me to assist with the filings after the consultation, the fees are generally as follows:

<ul>
	<li><strong>T1 Departure / Part-Year Resident Return — $270</strong></li>
          Canadian tax return for the year you became a non-resident of Canada.

	<li><strong>T1161 — $110</strong></li>
          List of properties owned when you left Canada, if required.
	
         <li><strong>T1243 — $220</strong></li>
          Deemed disposition / departure tax calculation, if applicable.
         
         <li> <strong>T2091 — $110</strong></li>
           Principal residence designation, if you owned and sold or changed the use of a                    Canadian home.
 
         <li><strong>T1135 — $250 to $350</strong></li>
           Foreign income verification statement, if required for years before becoming non-resident.

	   <li><strong>Section 217 Return — $450</strong></li>
	    Optional return to report Canadian pension income, CPP, OAS, RRSP/RRIF, or similar income, if beneficial.
   
           <li> <strong>NR5 Application — $250</strong></li>
             Application to reduce Canadian withholding tax on pension income, if applicable.

	   <li><strong>CRA Correspondence / Residency Review Support — $140/hour</strong></li>
	     If CRA requests additional information or challenges your residency status.</ul>

The exact forms required will depend on your facts and the year you became a non-resident.

Thank you,]]></content:encoded>
						                            <category domain="https://madancpa.beautybrandbuilders.co/learn/"></category>                        <dc:creator>MadanCA Team</dc:creator>
                        <guid isPermaLink="true">https://madancpa.beautybrandbuilders.co/learn/canadiantaxforum/i-have-nothing-in-canada-except-for-my-canadian-bank-acct-living-in-the-us-presently-how-can-i-declare-as-non-resident-of-canada/#post-1386</guid>
                    </item>
				                    <item>
                        <title>Answer: options trading using investments in my NRSP account.</title>
                        <link>https://madancpa.beautybrandbuilders.co/learn/canadiantaxforum/options-trading-using-investments-in-my-nrsp-account/#post-1385</link>
                        <pubDate>Tue, 05 May 2026 20:29:32 +0000</pubDate>
                        <description><![CDATA[Hi Ashok,

Thank you for your message.

Assuming you are referring to your RRSP account, options trading may be permitted, but it depends on the type of option strategy and whether your ...]]></description>
                        <content:encoded><![CDATA[Hi Ashok,

Thank you for your message.

Assuming you are referring to your RRSP account, options trading may be permitted, but it depends on the type of option strategy and whether your financial institution allows it inside a registered account.

Generally, CRA permits certain qualified investments in an RRSP, including listed securities and certain exchange-traded options. However, more speculative strategies, uncovered/naked options, margin trading, or short selling are usually not allowed inside registered accounts because RRSPs cannot use margin or borrow funds.

You should first confirm with your brokerage whether the specific option strategy you want to use is allowed in your RRSP account.

If you would like tax advice on the risks, reporting requirements, and whether the activity could create tax issues, I recommend booking a 30-minute paid consultation for $140 + HST using the link below:

https://calendly.com/allanmadancpa]]></content:encoded>
						                            <category domain="https://madancpa.beautybrandbuilders.co/learn/"></category>                        <dc:creator>MadanCA Team</dc:creator>
                        <guid isPermaLink="true">https://madancpa.beautybrandbuilders.co/learn/canadiantaxforum/options-trading-using-investments-in-my-nrsp-account/#post-1385</guid>
                    </item>
				                    <item>
                        <title>Answer: US citizen worked one month in Canada, how do I get my withholding tax back?</title>
                        <link>https://madancpa.beautybrandbuilders.co/learn/canadiantaxforum/us-citizen-worked-one-month-in-canada-how-do-i-get-my-withholding-tax-back/#post-1384</link>
                        <pubDate>Tue, 05 May 2026 20:18:30 +0000</pubDate>
                        <description><![CDATA[Hi Luke,

Thank you for contacting us.

As a U.S. citizen who worked in Canada for approximately 5–6 weeks and had Canadian tax withheld from your pay, you may be able to recover some or...]]></description>
                        <content:encoded><![CDATA[Hi Luke,

Thank you for contacting us.

As a U.S. citizen who worked in Canada for approximately 5–6 weeks and had Canadian tax withheld from your pay, you may be able to recover some or all of the withholding by filing a Canadian non-resident personal tax return.

In most cases, the Canadian slip you received is likely a T4 slip reporting Canadian employment income and tax withheld. To claim a refund, you would generally need to file a Canadian T1 non-resident return for the year in question and report the Canadian-source employment income. The actual refund will depend on the amount of Canadian income earned, the province where you worked, the Canadian tax withheld, and whether treaty relief is available under the Canada–U.S. Tax Treaty.

For Canadian employment income, treaty relief may apply if your time in Canada and compensation meet the treaty conditions. However, this needs to be reviewed carefully based on your facts, including:

<ul>
	<li>Your total days physically present in Canada during the year</li>


	<li>The amount of employment income earned while working in Canada</li>


	<li>Whether your employer was Canadian or U.S.-based</li>


	<li>Whether the cost of your compensation was borne by a Canadian entity or permanent establishment</li>


	<li>The province where the work was performed</li>


	<li>The Canadian tax slip issued to you, such as a T4</ul></li>

Our fee to prepare and file a Canadian non-resident personal tax return is $270, plus disbursements and taxes, if applicable. If a treaty-based position or additional analysis is required, we can confirm the additional fee after reviewing your documents.

Please send us a copy of your Canadian tax slip and a brief summary of your work arrangement, including the dates you were physically in Canada and who your employer was. Once reviewed, we can confirm the filing approach and whether we expect a refund.

If you would like specific tax advice before proceeding, you can also book a 30-minute paid consultation for $140 plus tax here:

https://calendly.com/allanmadancpa

Kind regards,]]></content:encoded>
						                            <category domain="https://madancpa.beautybrandbuilders.co/learn/"></category>                        <dc:creator>MadanCA Team</dc:creator>
                        <guid isPermaLink="true">https://madancpa.beautybrandbuilders.co/learn/canadiantaxforum/us-citizen-worked-one-month-in-canada-how-do-i-get-my-withholding-tax-back/#post-1384</guid>
                    </item>
				                    <item>
                        <title>I have nothing in canada except for my canadian bank acct. Living in the US presently, how can i declare as non resident of canada</title>
                        <link>https://madancpa.beautybrandbuilders.co/learn/canadiantaxforum/i-have-nothing-in-canada-except-for-my-canadian-bank-acct-living-in-the-us-presently-how-can-i-declare-as-non-resident-of-canada/#post-722</link>
                        <pubDate>Sun, 03 May 2026 21:59:46 +0000</pubDate>
                        <description><![CDATA[I would like to declare as non-resident of Canada. I am a canadian citizen and a green card holder of US. I have no ties in Canada except for my canadian bank acct. I would like to know if I...]]></description>
                        <content:encoded><![CDATA[I would like to declare as non-resident of Canada. I am a canadian citizen and a green card holder of US. I have no ties in Canada except for my canadian bank acct. I would like to know if I can receive CPP and OAS. I have lived in Canada for over 35 yeard. If you are able to help me how much would this service cost?]]></content:encoded>
						                            <category domain="https://madancpa.beautybrandbuilders.co/learn/"></category>                        <dc:creator>Anonymous</dc:creator>
                        <guid isPermaLink="true">https://madancpa.beautybrandbuilders.co/learn/canadiantaxforum/i-have-nothing-in-canada-except-for-my-canadian-bank-acct-living-in-the-us-presently-how-can-i-declare-as-non-resident-of-canada/#post-722</guid>
                    </item>
							        </channel>
        </rss>
		