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Renouncing Your U.S. Citizenship? – Count ALL Your Assets

Renouncing U.S. citizenship raises the issue of whether U.S. exit tax applies and what that calculation includes.

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U.S. Transition Tax – A Fourth Update

April 14 2018

In mid-April, there is usually a race against time by taxpayers and accountants to meet U.S. tax filing deadlines. The normal U.S. tax filing deadline for the 2017 year for individuals and certain U.S. entities is Tuesday, April 17th (a few days later than the usual April 15th due to weekends and a U.S. holiday on Monday).  Entering the “race against time” this year is the Internal Revenue Service itself, who on Friday April 13th published more guidance on the U.S. Transition Tax, a mere four days before the filing deadline.  The IRS has been very active this winter and spring providing updates and guidance for the U.S. Transition Tax enacted by the Tax Cuts and Jobs Act in December.  Links to our blog entries on the previous updates are at the end of this blog.

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

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

US State and Local Tax Consideration for Canadian Businesses

September 1 2015

Often Canadian businesses are surprised to learn about the reach of US state taxing jurisdictions to assert tax on out-of-state taxpayers.  Since none of the 50 states were signatories to the Canada-US Income Tax Convention (the “Treaty”), they are not limited by the Treaty to taxing business activities in the US.  It is not uncommon to find a Canadian business subject to a state’s taxing jurisdiction and completely exempt from US federal income taxation because of the Treaty.

Canadian Corporations with US Business Activities, Federal, State And Corporate Returns (US), Nexus, US Tax