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International Tax advisory

Canadian farmers selling products in the U.S.

With an increasingly global farm commodity market and a lower Canadian dollar, Canadian farmers are finding it much easier to sell their products in the United States. However, it is important that producers are aware of potential U.S. tax issues and filing requirements, particularly if this is common practice on their farm operation.

Green farm land with varying grass lengths creating an interesting organic pattern.

International Tax advisory

Planning for U.S. expatriation – The ins and outs of IRC 877A

The past several years have been a wild ride for many U.S. taxpayers (and tax practitioners), in particular for those residing outside of the country. While there are a surprising number of U.S. persons still grappling with becoming compliant, in general, the progression to considering expatriation has been somewhat predictable, as follows.

Todd King Jun 10, 2016

266 PEOPLE

International Tax advisory

RESP and TFSA Accounts for U.S. Citizens

Recently, Canada and the U.S. reached an agreement providing that Canada will assist with the collection and reporting of information to the U.S. Internal Revenue Service (IRS) on U.S. persons living here in Canada in order to comply with the U.S. Foreign Account Tax Compliance Act (FATCA). See our February U.S. Tax Flash for details on the agreement.

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International Tax advisory

Snowbirds and the Closer Connection Exception

Fall is the time of year when Canadian snowbirds pack up and head south for the warmer winter in the U.S. Some limit their stay to a maximum of 182 days, under the mistaken belief that this will avoid being considered a resident of the U.S. for income tax purposes (and conveniently brings them home just in time for spring). Many do not realize that the U.S. residency rules for income tax purposes involve a much shorter time period.

Shelley Smith Dec 5, 2013

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International Tax advisory Transfer pricing

Financing a U.S. Subsidiary: Debt vs. Equity

Canadian corporations seeking to expand their operations often look southward to grow their business. By expanding into the United States, Canadian corporations can potentially gain access to a much larger market than is available in Canada. For a variety of valid reasons, Canadian corporations often choose a U.S. corporation as a vehicle for expansion into the U.S. But once this structural decision is made, the question becomes, how to finance the U.S. operations?

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International Tax advisory Transfer pricing

Our American Customers: the Watchdogs of the U.S. Tax System

With today’s technology, it is becoming increasingly easy to sell products to individuals and companies all around the world. Many Canadian companies have developed great business relationships with U.S. customers, selling a wide variety of goods.

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International Tax advisory Transfer pricing

U.S. Tax Treatment of Certain Canadian Tax-Deferred Accounts

While many U.S. citizens living in Canada have recently become aware of the requirement to file annual U.S. individual income tax returns, they may not be aware of the specific filing requirements in regard to certain registered investment plans held in Canada.

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International Tax advisory Transfer pricing

Cross Border and International Tax Planning

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International Tax advisory Transfer pricing

U.S. Estate Tax Issues for Canadians

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International Tax advisory Transfer pricing

Amendments to the Canada-US tax treaty

The fifth Protocol to the Canada-US Income Tax Convention was signed on September 21, 2007, and is anticipated to come into force in early 2008. With certain exceptions, the amendments will take effect for taxable years commencing after the calendar year in which the Protocol comes into force.

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International Tax advisory Transfer pricing

Canadians owning U.S. real estate

A growing number of Canadians own rental property or personal real estate in the United States. Such owners should ensure they are aware of the applicable US income tax requirements. Taking steps to understand and comply with these US tax rules could result in significant US income tax savings and avoidance of penalties and interest.

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