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US Transition Tax – Next Update

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.

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US Education Savings Plans for Residents of Canada

March 22 2018

Canada and the US have similar tax laws for education savings plans. Unfortunately, neither recognizes the each other’s plans the same as their own. For example, a US education savings plan, such as a “529 Plan,” has Canadian tax reporting requirements which are not applicable to a Canadian Registered Education Savings Plan.

US Citizens Resident In Canada

US Transition Tax – Update

March 14 2018

On March 13th, the Internal Revenue Service provided further guidance on how US taxpayers should report activity subject to the US Transition Tax on their 2017 US income tax returns.  Our previous blog describing the tax and its impact to US taxpayers can be found HERE. This IRS guidance references earlier IRS updates and provides instruction on how to complete US federal income tax returns, file elections and make US federal income tax payments.  Full details of the IRS’s guidance can be found at the link below. 

Transition Tax

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