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IRS Regulations Clarify 250A Deduction for Individual Owners of Non-U.S. Corporations Subject to GILTI

Last fall, we wrote about the U.S.’s Global Intangible Low Taxed Income (“GILTI”) and its’ adverse tax impact on U.S. persons that own non-U.S. corporations.  

GILTI impacts U.S. persons resident in Canada who own Canadian and other non-U.S. corporations. Without effective tax planning, combined U.S. and Canadian tax rates approaching 85% could occur as early as 2018. 

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Warren Dueck Joins Global News Morning Calgary to Discuss the new U.S. Tax Reforms

May 29 2018

Warren Dueck joins Global News Morning Calgary to discuss the new U.S. tax reforms and how many Canadian residents may be facing new tax bills.

Press Room, US Tax Law

U.S. Transition Tax – Next Update

April 3 2018

On April 2nd, the IRS and U.S. Treasury issued more guidance on the U.S. Transition Tax enacted by the Tax Cuts and Jobs Act (“TCJA”) in December 2017.  As the U.S. moves to a territorial tax system for profits earned outside the U.S., this provision assesses a tax rate on accumulated earnings and profits in specific non-U.S. corporations owned by certain U.S. corporations and U.S. individuals.

Repatriation Tax, Transition Tax, US Citizen, US Citizen Living Abroad, US Citizens Resident In Canada, US Corporation, US Tax Law

US Transition Tax

February 27 2018

In December 2017, the US enacted The Tax Cuts and Jobs Act (“TCJA”). Amongst many changes to US tax law is a move to a territorial tax system where US corporate shareholders of non-US corporations can repatriate profits earned outside the US without additional US tax. As part of this transition, many US shareholders are now subject to US federal income tax on past profits remaining in certain non-US corporations commonly referred to as Transition Tax (or Repatriation Tax).

Repatriation Tax, Transition Tax, US Tax Law
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