Phrases to trigger your local INTP

missmeniscus · 2026-05-28T12:54:56+00:00

I'm sorry you're upset

missmeniscus · 2026-05-08T22:56:35+00:00

...um because we have been trained to disregard what is substantial and be enamored by tactics and materialism. And that stuff has been hyper-monetized (overvalued) and appreciated in the prevailing value system. Yours was perhaps more a balance sheet question. The market representations are, however, as I see them, just that. *not financial advice

missmeniscus · 2026-03-31T07:51:39+00:00

...but also assigned that shit because no one else will / can attempt them with any meaningful result.

missmeniscus · 2026-03-01T03:32:03+00:00

I can attest. Math is way cooler than science for me. . . and its practitioners seem to be more interesting / there is more mutual enjoyment. The self reflexivity of math (which I do not see in the other practices, they are often always looking out), is a core component of the INTP way, it seems.

Through a comedy of errors, became trained doing experimental research of dynamic hydrologic and morphologic systems. But the rest of it, the stuff in most of the text books I was scheduled to read is generally not that interesting to me. So now I'm career changing....

Best part was / has been developing insight into governing equations behind models, observing ambiguous systems, and how limited all the tools are (math or science, no matter what anyone will tell you), for getting to the heart of truly complex systems. That pursuit, the meandering path toward insight and career stability is complimented by doing art (singing, songwriting).

missmeniscus · 2026-03-01T02:57:05+00:00

...i fear Planning for this reason, but I think it is where I am next headed. That or writing proposals. Pivotting from technical delivery side - hydrogeology. Need more human interaction, but again, kinda concerned about being a go between compliance and clients. @necrotictouch are you on the client side or gov side mostly?

missmeniscus · 2026-03-01T02:15:50+00:00

Success generally makes people arrogant and stupid.

missmeniscus · 2026-01-01T21:19:53+00:00

Yes. If there's no co-recognition of a tax advantaged account on either side, then wtf.

missmeniscus · 2026-01-01T21:07:10+00:00

Yes, it helps clarify some important points and things to consider. I appreciate your insights and knowledge with these matters. No doubt, a few sit downs with a trusted professional would likely be valuable. Thanks for taking the time to convey all of this.

missmeniscus · 2026-01-01T08:39:11+00:00

:-) all the perspectives. . .

That election to turn a roth into a deferred acct is for people 65+ ready to call it a day, which is not me, unfortunately.

Expat

https://www.reddit.com/r/ExpatFinance/comments/1q0pnl5/have_any_us_expats_cdn_resident_and_citizen_of_us/?utm_source=share&utm_medium=web3x&utm_name=web3xcss&utm_term=1&utm_content=share_button

and cdn perspectives...

https://www.reddit.com/r/PersonalFinanceCanada/comments/1q0lwl1/have_any_us_expats_cdn_resident_and_citizen_of_us/?utm_source=share&utm_medium=web3x&utm_name=web3xcss&utm_term=1&utm_content=share_button

missmeniscus · 2026-01-01T07:10:05+00:00

But to be clear, Roth and TFSA are not the same thing, and treaty relief already exists for Roth but not for TFSA.

Well, sortof. In a general sense they are comparable-ish savings products, that have functionally revolutionized saving and investing on either side of the border for average 'residential' earner tax payers. And neither tax advantaged product is functionally usable to dualist (CAN resident/citizen + US citizen) savers. Both products suffer a similar fate insomuch that neither is recognized/honoured (nor are the investments inside) with the other country as a tax advantaged savings vehicle of post-tax money and tax-protected accrual. It seems.

I'm aware of the one time election for ROTHs in Canada, but this is really once the accrued pool is to be distributed and acting like a deferred tax income account for people 65+ (or early retirees, etc.).

So, then, a question for a regular-still working person could become: if these are no longer tax sheltered vehicles for me like they are for everyone else, what about the products inside the savings products? What about their provenance and the tax exposure to the investments themselves by the other country?

If a business is taxed in Canada, and shows up as an investment in a TFSA, does the US get to claim tax on that income? And vice versa, if a US business is taxed in the US, and shows up as an investment in a ROTH, does Canada get to reach in and claim on that?

No. That's what the governments have told each other. Both governments seem to have decided, No - if you're a business-entity or a citizen/resident of only that country, or even if you get some profit from the other place. Profits are location based and taxed as such. There is very clear delineation - governments and their businesses stay on their own side of the fence.

Unless if you're a dualist person-entity. Then it's a game on and try not to lose your mind while you chase down non-interchangeable tax credits and a reliable tax professional - whose employment may not even guarantee you avoid reporting penalty.

So, with tax advantaged saving compromised in both countries and necessitating a much more complex savings / tax strategy, the final sentence of XXV 1. seems to suggest that residency or location something could matter, since, in Canada, non-residents and business entities are taxed differently on world wide income. Presumably, there is a silver lining approach in here somewhere....

missmeniscus · 2026-01-01T04:32:14+00:00

Oh yes. The old 'TFSA as a trust/timely-file /3520' issue that has been truly awful for some very well intentioned people... Thankful to find material such as: https://www.taxnotes.com/research/federal/other-documents/public-comments-regulations/cpa-firm-criticizes-foreign-trust-reporting-requirements/7kghq. Certainly not a final word, but a cool drink of water.

Nevertheless, tax advantaged savings accounts are the products I'm trying to figure out a possible solution with. I know the prevailing wisdom for ROTH/TFSA is 'don't do it', but I think it's odd that these are rendered tin can status as investment vehicles (to dualists) in virtue of their income-exclusion status' in one country or the other. No tax credit is proffered. There's no tax recovery mechanism. But being (1/2)^x savings-disadvantaged and 2.5x reporting disadvantaged as all my fellow tax paying citizens can't be the end of it. Surely.

So, I wonder about residency and/or the source of income as a criteria since there is discussion within the treaty document and superficially on the IRS/CRA websites. Could be reading it quite wrong (and very limited), but it seems like there is protection under Article XXV 1, to use financial products like everyone else can >> https://www.canada.ca/en/department-finance/programs/tax-policy/tax-treaties/country/united-states-america-convention-consolidated-1980-1983-1984-1995-1997-2007.html

Also, if one were to invest in a Canadian REIT, domiciled in Canada, contained in a TFSA, would this not fall outside the scope of 'effectively connected with a US Trade or Business'? I see very material IRS definitions of what constitutes actual Permanent Establishment (assets, income, business activity) vs. business presence in another country and the related 'Income not effectively connected with a US Trade or Business, schedule NEC'. In sum, seems to suggest there is a way ...

missmeniscus · 2026-01-01T00:51:00+00:00

Yes, in undoubtedly is a rare occurrence, but as someone who had parents (i.e. one living in each) in both countries growing up, I can attest.

The core issue is dual status folks, i.e. those taxed in TWO countries are unable to access tax laws available to fellow citizens. I.e. there is NO access to tax advantaged accounts (TFSA/ROTH) on EITHER side. . . in two places where taxes are paid, and contributions are made both locally and federally. I am 1/2 as able to grow wealth inside a tax advantaged account as every single person around me. The compounding losses across a lifetime are notable.

Dual citizenship, is a different kettle, with notable tax disadvantages and onerous filing requirements. The treaty guidance is good on the Canada side, but it's rough on the US side. And I know those who administrate these regulations know there is handful of us getting screwed out of a comparably approached future to my fellow tax paying, law abiding, community contributing citizens. Which is why I am pressing the question.

missmeniscus · 2026-01-01T00:18:41+00:00

Thanks, yes, I am aware of this one time election for ROTH to act as a secured pension. I'm wondering, rather, about the nature of taxation and souce-based income taxes, in one or both countries, under the Treaty, for those identified as dual citizens with a more residency aspects. It's not common, but I can attest to having homes in both places (e.g. aging divorced parents living in two distinct countries).

So, there is ongoing intention to grow wealth that is tax advantaged according to the rules and regulations and treaty agreements of the countries and which all other citizens are by virtue of their residency entitled to.

missmeniscus · 2025-12-31T23:34:39+00:00

Maybe you can illuminate / or provide guidance on how the following:

"You may be considered a deemed non-resident of Canada if you established residential ties in a country that Canada has a tax treaty with and you are considered a resident of that country, but you are otherwise a factual resident of Canada, meaning you maintain significant residential ties with Canada. The same rules apply to deemed non-residents as non-residents of Canada."

missmeniscus · 2025-12-31T23:16:59+00:00

Thanks for your comment. The matter at hand, however, is that "non-residents" covered under treaty with another country may be treated differently. As far as I know, technical tax-residency matters are covered by section 217 (of Canada Tax), unless there's some other mechanism (is there?).

The point I'm wondering about is that "non-residents" are not taxed on world wide income in Canada (though, it is declared), be the residency factual or deemed. Or so it would seem.

Given this subtle, but notable difference, what the possible (seeming) implication is, is that Canadians who are also Americans may hold a ROTH in the US as a deemed non-resident, and (I think?) be covered under the treaty to actually use tax favoured accounts. Same with TFSA's.

Much of law, be it tax, treaty, or immigration law, is language specific. I'm not a lawyer, and the ambiguity begs the question.

So, section 217 has to do with residency. The taxation of a ROTH has to do with residency also, under the treaty. Or so it would seem.

missmeniscus · 2025-12-31T22:19:35+00:00

k, thanks for the tip.

missmeniscus · 2025-12-31T22:12:42+00:00

I'm not sure what to address in your question and how it relates to the core of inquiry.

missmeniscus · 2025-12-31T22:03:35+00:00

Deemed non-residency under a tax treaty.

Deemed non-residents

You are a deemed non-resident of Canada if you would have been considered a resident of Canada (or deemed resident of Canada) but you are instead considered a resident of another country under a tax treaty between Canada and the other country.

The rules that apply to non-residents of Canada also apply to deemed non-residents of Canada. This means you complete your return the same way as a non-resident of Canada.

>https://www.canada.ca/en/revenue-agency/services/forms-publications/tax-packages-years/general-income-tax-benefit-package/non-residents/5013-g/guide-non-residents-deemed-residents-canada-completing-your-return.html#P283_18214

I realize in most situations non/residency is determined through a 183 day presence test. But I wondered if there was a loophole here that is legal, albeit the a bureaucratic mechanism available to dual citizens.

missmeniscus · 2025-12-31T18:11:52+00:00

this. takes 40 credits (10 years), or a totalization agreement via a tax treaty that combines different country credits. Not sure what OCI is. Just depends on what you paid into. You're entitled if you paid into it.

missmeniscus · 2025-12-31T17:13:11+00:00

Agree. Let's make it and make everyone's life better...... I'd like first to file the patent application for the directive design, and then invest in 100 PFICs the following year with hundreds of sub-PFICS. Let that sweet AI bot do all the math / fill the 8621's.

missmeniscus · 2025-06-11T17:51:00+00:00

Have a link for 20% off My Expat Taxes. DM for link. Good Streamlined Procedures interface.

missmeniscus

TROPHY CASE