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Recent Publications - U.S. corporate tax

Recent Publications

January 15, 2024

2024 tax deadline calendar

Navigating the various Canadian and U.S. tax deadlines throughout the year can be tricky. Our 2024 tax deadline calendar provides a monthly snapshot of important dates that could apply to you or your organization. It can help you stay on top of your obligations, discover overlooked deadlines and avoid unwanted surprises.

November 22, 2023 by Rosa Maria Iuliano

2023 Fall Economic Statement: Tax measures

Deputy Prime Minister and Finance Minister Chrystia Freeland delivered the 2023 Fall Economic Statement (FES) in the House of Commons on Tuesday, Nov. 21, 2023.

September 12, 2023 by Mandeep Gaheer

Bring it back – Repatriating profits from Canada to the U.S.

In our latest Tax Alert, we take a look at repatriation planning. Specifically, we examine the most effective tax strategies for a Canadian subsidiary (“CanCo”) to repatriate profits to its U.S. parent corporation (“USCo”).

May 25, 2023 by Dean Morris

Transfer pricing and small‑ to medium‑sized enterprises

Much like large global companies, small‑ to medium‑sized enterprise multinational enterprises (MNEs) may be subject to complex transfer pricing requirements. As governments increasingly seek to protect their tax base, our new Tax Alert focuses on the transfer pricing challenges and considerations facing small‑ to medium‑sized enterprise MNEs.

March 14, 2023 by John F. Oakey

FBAR penalty – A welcomed decision by the Supreme Court

On Feb. 28, 2023, the U.S. Supreme Court ruled in the case of Bittner v. United States1 that the non‑willful penalty for failure to file the Foreign Bank and Financial Accounts (FBAR) report was on a per report basis, not per account basis.

January 18, 2023

2023 tax deadline calendar

With so many Canadian and U.S. tax deadlines spread throughout the year, everyone could use an occasional reminder. Our 2023 tax deadline calendar provides a convenient month‑by‑month summary of key dates that could apply to you. You might even notice a few obligations that slipped your mind. If you don’t like getting caught by surprise, you’ll love our tax deadline calendar.

December 13, 2022 by Shelley Smith

Borders without (tax) boundaries – Navigating U.S. returns in a cross‑border setting

United States citizens and Green Card holders are both considered U.S. persons, regardless of where they live. U.S. persons living outside the U.S. (such as in Canada) must continue to file U.S. tax returns annually, even if they have no income from the United States. For such individuals, there are mechanisms to avoid or reduce U.S. tax exposure and, in many cases, end up owing no U.S. tax at all. Still, failure to file returns, related forms and certain foreign information reporting can result in significant penalties.

April 26, 2022 by Mandeep Gaheer, Hassanatu Timbo

Budget 2022: Adapting international tax measures

Canada is one of 137 members of the Organization for Economic Cooperation and Development (OECD) that have joined the two-pillar plan for international tax reform. Budget 2022 reiterates the government’s commitment to address the challenges arising from the digitalization of the economy, and to work towards implementing both Pillar One and Two.

November 19, 2021 by Shaun Andresen

A streamlined procedure does not clear a GILTI conscience

In December 2017, President Trump signed the Tax Cuts and Jobs Act (TCJA) into law. The TCJA made significant amendments to the Internal Revenue Code (IRC). Among them was the introduction of a transition tax under IRC section 965—a tax on accumulated earnings of certain foreign corporations in the hands of U.S. shareholders. This new tax marked a transition to taxing the active income of foreign corporations.

October 6, 2020 by Kevin Tippett

Seller beware: tax issues for Canadian residents selling U.S. real estate

For a few years following the 2008 financial crisis, we saw many investors and snowbirds purchasing U.S. properties to take advantage of real estate bargains and a weak U.S. dollar. Over a decade has passed, the Canadian dollar has weakened, and with limited ability—or desire—to travel to the U.S. due to COVID-19 we are noticing a significant increase in U.S. real estate sales by Canadian residents. The situation provides an incentive to review some of the common U.S. tax issues when a Canadian resident sells U.S. real estate.

March 13, 2020 by Trevor Reid

IRS provides relief for U.S. citizens & residents with certain Canadian registered savings accounts

U.S. citizens and residents who own foreign trusts are often caught by the rules of the Internal Revenue Code section 6048, which requires those individuals to report transactions with, or ownership of, foreign trusts. This information is reported on Forms 3520 and 3520-A. Non-compliance with these laws comes with steep penalties starting at $10,000 per missed filing.

March 10, 2020 by John F. Oakey

U.S. citizens beware – IRS wants to know about your virtual currency

The U.S. government, along with most governments, has invested resources in understanding cryptocurrency and is developing policies to deal with virtual currency. As of today, Bitcoin still remains the most invested virtual currency on the market with a market cap of approximately $200 billion.

December 12, 2019 by Dan Roberts

Managing U.S. withholding tax requirements for Canadian service providers

Are you a Canadian service provider (either an individual or a corporation) performing services for a U.S. business? If so, you could be considered a foreign person to that U.S. business, and the payments you receive may be subject to a U.S. 30 per cent federal withholding tax.

November 20, 2019 by Shelley Smith

Canadians doing business in the U.S.

​With the economy in Alberta the way it is, it is no surprise that oilfield workers are searching for business opportunities south of the border. But they and any other Canadians seeking to establish their business in the U.S. may not realize that there can be a lot of red tape to deal with. Proper planning is key before entering into this type of venture.