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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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Steven Flynn Comments on BC’s New Speculation and Vacancy Tax and the Impact on Foreign Nationals who own Canadian Real Estate

February 26 2019

Canada Revenue Agency (CRA) is poised to receive significant data from the BC government that will help tie home ownership to income declarations. While BC's speculation and vacancy tax is a measure to address the housing crisis in major urban centers in BC, it can also have an impact on “satellite” families who declare very little as Canadian income and those who own a secondary urban home that remains empty for most of the year.

Canada Revenue Agency, Canadian Real Property, Canadian Tax Law, Tax Liabilities

British Columbia Speculation and Vacancy Tax

January 28 2019

Owners of BC residential property need to be aware of the new 2018 British Columbia Speculation and Vacancy Tax affects and how to apply for exemptions.

BC Speculation and Vacancy Tax, Canada Revenue Agency, Canadian Real Property, Canadian Tax Law

Global Intangible Low-Taxed Income (“GILTI”)

October 9 2018

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.

Federal, State And Corporate Returns (US), GILTI (Global Intangible Low Taxed Income), IRS (Internal Revenue Service), Tax Liabilities