Tax Trends
Investing with a Foreign Broker and Buying Canadian Shares
Foreign brokers can attract Canadian investors, perhaps because of low management fees. The foreign broker may purchase…
What is my U.S. taxable year (as it relates to certain Canadian corporations)?
The recently enacted U.S. Tax Cuts and Jobs Act introduced new IRC §965, “Treatment of Deferred Foreign…
IRS Provides Some Relief For U.S. Taxpayers Abroad in Meeting the Repatriation Tax Payment Deadlines
Yesterday, April 2, 2018, the IRS released Notice 2018-26, the long-awaited additional guidance related to the one-time…
Understanding U.S. Due Dates, Extensions and Payment Dates
The due date for a U.S. personal income tax return will depend on both the residence of…
Understanding the U.S. Days Counting Test and U.S. Tax Residency
In most countries an individual’s tax residency is determined by their residential ties, which considers one’s own…
IRS Announces the end of the Offshore Voluntary Disclosure Program though Streamlined is still around – for now
On March 13, 2018 the Internal Revenue Service announced (IR-2018-52) that it will close the 2014 Offshore…
The importance of E&P – Will you be paying the right amount of tax to the IRS?
An accurate determination of “earnings and profits” (E&P) of a foreign (i.e., Canadian) corporation is often an…
IRS Form 5472 : An easy but expensive filing obligation to overlook?
Recent media coverage, as it relates to U.S. tax in Canada, has almost entirely focused on the…
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…
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Taxation of Real Estate in Canada
Towards Greater Fairness in Taxation: A Model Taxpayer Charter
Taxation of Trusts and Estates: A Practitioner’s Guide 2024
Taxation at Death: A Practitioner’s Guide, 2021
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