US Transition Tax
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).
Moving from Canada to the US? Save Money with Canada Pension PlanFebruary 6 2018
Moving to another country presents significant tax planning opportunities, especially if you are moving from Canada to the US. A commonly overlooked tax strategy for incorporated professionals and other intercompany transferees is to avoid US Social Security and Medicare by continuing their coverage under Canada Pension Plan. The tax savings can reach more than US$10,000 annually and more for up to 5 years for qualifying persons.Cross-Border Tax, Form CPT56, Social Security Agreement
US Tax Reform – Getting Closer to the EndDecember 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 hereUS Citizen, US Citizens Resident In Canada, US Tax Law, US Tax
Is the interest expense deductible for US non-resident aliens owning a US real property interest?November 29 2017
Loaning between business entities is a widely-adopted business strategy in the real estate industry. Multiple levels of entities are often chosen in a business structure. U.S. limited liability companies (“LLC”) are commonly used to hold U.S. real property interests. When foreign investors are involved for various reasons (i.e., asset protection), foreign investors use a non-U.S. corporation that is treated as a disregarded entity for U.S. federal income tax purposes to be the sole owner of the U.S. LLC.US Tax Law