Your business has decided to enter the Canadian market. Congratulations, this is an important step forward! However, launching in Canada is not without its risks and complications.
September 11, 2019 by Mike Hayward
On Sept. 6, the Internal Revenue Service (IRS) announced a new tax compliance program entitled “Relief Procedures for Certain Former (U.S.) Citizens” (Relief Procedures).
July 4, 2019 by John F. Oakey
The IRS announced on June 4, 2019, that it will end its tax transcript faxing service in June and will amend the Form 4506 series to end third-party mailing of tax returns and transcripts in July. The announcement indicated that transcripts have become increasingly vulnerable as criminals impersonate taxpayers or authorized third parties to file fraudulent returns for refunds.
March 7, 2019 by Todd King, Martha MacRae
As an update to our article Planning for IRC 951A: No Reprieve for the GILTI, the IRS has recently released regulations that provide a significant benefit to many US individual taxpayers grappling with the new GILTI regime.
February 13, 2019 by Todd King, Martha MacRae
This article will provide an overview of the GILTI (Global Intangible Low-Taxed Income) rules and their implications, as well as exploring planning options that should be considered by those subject to the rules.
January 14, 2019 by Trevor Reid
The IRS warned recently that the Streamlined Filing Compliance Procedures may end. The message is clear: don’t wait any longer.
December 20, 2018 by Darlene Shaw
The recent ruling of the Supreme Court of the United States in South Dakota v. Wayfair, Inc., while receiving little coverage here in Canada, may have a substantial impact on how Canadian companies do business in the United States. In what may be a game changer for online retailers, the ruling has opened the door for individual states to enforce sales tax collection on sales shipped into their state, even where the seller has no physical presence.
In December 2017, U.S. lawmakers passed the Tax Cuts and Jobs Act, the most comprehensive U.S. tax reform in more than 30 years. This infographic offers a basic guide to recent changes that may be applicable to U.S. citizens living abroad.
August 24, 2018 by Shawn Strandberg
The Internal Revenue Service (IRS) has announced it will begin to wind down the 2014 Offshore Voluntary Disclosure Program (OVDP) and close it entirely on Sept. 28, 2018.
March 14, 2018 by Martha MacRae, Todd King
From a taxation perspective, the period from July 2017 to February 2018 has been one of the most tumultuous in recent history for Canadian private company owners. For those who also have the privilege of being U.S. citizens or resident aliens, things have gotten downright ludicrous. In a rush to pass into law the most sweeping tax reform in a generation, U.S. lawmakers have stuck U.S. citizens resident in Canada with retroactive, double taxation, the elimination of much of the tax deferral previously available in their companies, a looming April 17th payment deadline and virtually no rules or regulations to guide them through the chaos.
The Honourable Bill Morneau, Minister of Finance, today tabled his third budget – “Equality + Growth: A Strong Middle Class” – which supports the Government’s people centered approach.
The highly anticipated budget released draft legislation related to passive income – the topic that has been on the minds of business owners, investors, and advisors since the July 18, 2017 Finance release which first introduced the subject. The budget does not propose changes to tax rates at the business or personal level. The budget focused on five key spending areas – growth, progress, reconciliation, advancement and equality.
From changes to passive investment income (that weren’t quite what was expected) to an absence of response to U.S. tax reform, here are some highlights from Budget 2018.
December 21, 2017 by Kevin Tippett
*Updated January 9 2017
On November 2, 2017, the Ways and Means Committee of the U.S. House of Representatives released a tax reform bill entitled The Tax Cuts and Jobs Act. Since then, the House and Senate Tax Cuts and Jobs Act Conference Committee released its final version of the legislation that is expected to become law in the coming days. It is the most comprehensive U.S. tax reform in more than 30 years.
December 19, 2017 by Shelley Smith
If you have worked in both Canada and the United States or are contemplating a move to the U.S. after years of working in Canada (or vice versa), you may wonder about paying into both the Canada Pension Plan (CPP) system and the U.S. Social Security system. Will you be able to collect pensions from both countries?
December 19, 2017 by Guy Desmarais
The Department of Finance released its long-awaited proposed amendments to the tax on split income (TOSI) rules on December 13. The release completes a tumultuous year for small business owners, tax professionals, Department of Finance officials, Members of Parliament and the Minister of Finance. The initial July 18 proposals and the short consultation period precipitated a groundswell of consternation and frustration.
November 23, 2017 by Nadia Pulla, Salome Victor
Topics include:
September 28, 2017 by John S. Lee
On September 27, 2017 the Republican Party released their long anticipated proposal for U.S. tax reform. The key takeaways of the framework have been summarized below. Please contact your local Collins Barrow U.S. tax advisory professional if you have any questions and to find out how these proposals may impact you and your U.S. or cross-border business.
September 27, 2017 by Ralph Neate
From an investment perspective, mutual funds and exchange-traded funds (ETFs) make sense for many Canadians. They allow them to reduce investment risk by diversifying their holdings through exposure to multiple industries and sectors of the economy, without the need to hold many individual stocks and bonds.
September 27, 2017 by Jonathan Gehrts
U.S. persons (U.S. citizens or green card holders) living in Canada or abroad who have investments outside the U.S. should be aware of the potentially onerous tax filing requirements imposed by the IRS, and how those rules will apply to their investments. IRS rules can be particularly complex when investments in foreign companies or funds earning passive income are involved.
This article expands upon the discussion in the companion piece, “U.S. tax pain: Canadian mutual funds and ETFs,” in this U.S. Tax Alert. This article digs deeper into the intricacies of the definitions and the filing requirements for PFICs and CFCs.
June 12, 2017 by Rainer Vietze
Canada has over 90 bilateral tax treaties and over 20 bilateral Tax Information Exchange Agreements in force, with at least a dozen more treaties or agreements in the negotiation stage. This fact alone highlights the importance such agreements play on the global tax stage. Not surprisingly, Canadian multinationals and Canadian subsidiaries of foreign multinationals have long understood the impact tax treaties may have on how their cross-border intergroup transactions will be taxed.