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U.S. citizens abroad who own an interest in a Controlled Foreign Corporation (“CFC”) have been unfairly targeted by two provisions of the U.S. tax reform that was legislated at the ...
Doing Business Globally: A Tax Update
In June 2018, in conjunction with hosting the international tax conference of Nexia International – a global network of independent accounting and consulting firms and one of the top ten global ...
GILTI or Not GILTI: A guide for U.S. expatriates living in Canada
First, expatriate U.S. citizens who owned a direct or indirect interest in a Canadian corporation had to deal with an unfair transition tax on the amount of earnings and profits ...
Do you own a U.S. enterprise? You may be required to complete the BE-12 benchmark survey by May 31, 2018
A U.S. business enterprise includes any organization, association, branch, or venture which exists for profit making purposes or to otherwise secure economic advantage, and any ownership of any real estate ...
The new income sprinkling rules: Part 3 – The third, fourth and fifth exceptions from the TOSI rules
In parts one and two of this series, we looked at the main changes to the legislation, as well as the first two exceptions from the TOSI rules. In part ...
The new income sprinkling rules: Part 2 – The first and second exceptions from the TOSI rules
New legislation regarding the use of income sprinkling rules came into effect on January 1, 2018. Referred to as the “Tax on Split Income”, or “TOSI”, the intention of the ...
The new income sprinkling rules: Part 1 – What has changed under the new TOSI legislation?
On December 13, 2017 the federal government released legislation with the intent to simplify the income sprinkling rules (referred to as the Tax On Split Income or TOSI) previously released ...
Dealing with Canadian real estate owned by a non-resident? Know the process to ensure you avoid costly errors
Non-resident individuals and corporations have recently invested in a high volume of Canadian real estate properties. Despite the high number of non-resident owners, many professionals in the real estate industry, ...
Maximize your real estate investments in 2018: Our top 10 financial management tips
While 2017 saw a bit of a slump for residential properties in Canada, certain markets remained strong (Vancouver, for instance), while real estate investment properties across the country were largely ...