U.S. citizens who own an interest in a Controlled Foreign Corporation (“CFC”) have faced a number of challenges under the U.S. tax reform bill which became law near the end of 2017. First, expatriate U.S. citizens who owned a direct or indirect interest in a Canadian corporation had to deal with an unfair transition tax ….
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 which is held for profit making purposes*. If this applies to you, you may be required to complete the BE-12 benchmark survey by the end ….
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 these rules. In part three, we’ll be examining the final three exceptions, and share a flowchart to demonstrate how and if the new rules will apply to your family. Third ….
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 legislation is to prevent the allocation of income to family members who are not involved in a business. In part one of this series, we ….
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 on July 18, 2017. The intention of the legislation is to prevent the allocation of income to family members who are not involved in a ….
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, including brokers, agents and lawyers, are unaware of the extensive taxation responsibilities of vendors and purchasers when a non-resident of Canada is selling Canadian real ….
Cannabis, commonly known as marijuana, is currently legal to use for medical purposes in Canada. The upcoming legalisation of recreational cannabis in Canada has created global interest in this new market. Since 2001, the use of cannabis for medical purposes has been legal in Canada. In July of 2018, the Canadian Government is expected to ….
While 2017 saw a bit of a slump for residential properties in Canada, certain markets remained strong (Vancouver, for instance), while investment properties across the country were largely cushioned from the blow. Beginning in Q2 of 2017, Toronto residential real estate was among the hardest hit, impacting many of our clients. As 2018 progresses, a ….
Amid sizzling real estate markets in places like Toronto and Vancouver that have driven prices North of the border sky high, Canadians have been looking South for opportunities to profit on better values in real estate investments. Recent changes to the U.S. tax law should cause Canadians who are organizing U.S. real estate partnerships and ….
The recent U.S. tax reform has provided Canadian-based multinational businesses some powerful incentives to shift production to the U.S. – lowered tax rates, particularly for U.S. exporters, and accelerated write offs for capital investments – are sending the message that the U.S. is open for business again. In Part 1: Recent U.S. tax reform impacts ….