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

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

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

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US Transition Tax – Next Update

April 3 2018

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

US Tax Reform – Getting Closer to the End

December 16 2017

Quite the week for tax professionals in Canada and the US.  On Wednesday, Finance Minister Bill Morneau provided guidance on how Canada’s income splitting rules will apply to private corporations.  You can read more about it here

US Citizen, US Citizens Resident In Canada, US Tax Law, US Tax
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