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Global Intangible Low-Taxed Income (“GILTI”)

The December 2017 U.S. tax reform included a provision to subject to U.S. tax the earnings of intellectual property owned by U.S. investors outside the US. 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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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