Internal Revenue Bulletin:  2010-13 

March 29, 2010 

TAX CONVENTIONS


Table of Contents

Rev. Proc. 2010-19 Rev. Proc. 2010-19

This procedure provides guidance for taxpayers emigrating from Canada who wish to make an election for U.S. federal income tax purposes under paragraph 7 of Article XIII (Gains) of the US-Canada Treaty with respect to property that is subject to Canadian departure tax under Canada’s deemed disposition rules. The effect of the election will be to relieve double taxation with respect to the property by either giving the taxpayer an adjusted basis in the property for U.S. federal tax purposes or the ability to accelerate U.S. federal income tax on such property at the time of emigration from Canada.


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