Understanding Constructive Share Ownership
The Tax Cut and Jobs Act (TCJA) has significant implications for United States persons who own shares…
Changes to U.S. “Kiddie Tax” Rules
With both the increases in Canadian personal tax rates, over the last few years, and the new…
Do You Owe Money to the IRS? You May Lose Your US Passport
If you are a U.S. citizen and you have a “seriously delinquent tax debt” with the IRS,…
Are you GILTI? New U.S. Rules Impact U.S. Individual Shareholders of Canadian Corporations
“An Act to provide for reconciliation pursuant to titles II and V of the concurrent resolution on…
U.S. Tax Reform – Deemed Repatriation Tax and Individual Shareholders of Canadian Corporations
On December 22, 2017 President Trump signed into law, “An Act to provide for reconciliation pursuant to…
U.S. Corporate Tax Reduction – Impact on CCPC shareholders – Part II (GRIP)
This U.S. Tax Tip follows up on the US Tax Tip issued on November 30, 2017. The facts/assumptions…
Proposed U.S. Corporate Tax Reduction – Impact on CCPC Shareholders
Both the U.S Republican House and Senate tax plans (The Tax Cuts and Jobs Act, H.R. 1)…
Has Your ITIN Expired?
If you are a US nonresident alien and have filed a US income tax return, you most…
U.S. Tax Reform – Is It Permanent?
Ever since President Trump announced his candidacy for President, both he and the Republican Party have been…
Withholding Tax on Capital Distributions to Non-Residents
It is generally understood that income distributions by trusts to non-resident beneficiaries are subject to part XIII withholding…
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