On June 21, 2018, the U.S. Supreme Court ruled 5-4 in favour of allowing South Dakota to impose an e-commerce sales tax by Wayfair Inc. (“Wayfair”), a large online furniture ...
Update for CFC owners on mitigating the impact of U.S. tax reforms
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 ...
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 ...