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As part of the US’s 2017 Tax Reform Package, rules were passed to preclude certain US partnerships from deducting all or a portion of their US interest expenses. Below we ...
Increased compliance burden for US expatriates who own CFCs
The IRS has released new forms required for US citizens who own foreign (e.g. Canadian) corporations which are treated as Controlled Foreign Corporations (CFCs) for US tax purposes. The penalties ...
Relief Provided from GILTI tax for US Expatriates
As part of the US tax reform in late 2017, US citizens who owned Canadian corporations which are CFCs were subject to a repatriation tax on an amount approximating the ...
Taxation of cannabis businesses in the US: the do’s and don’ts
While a number of US states have legalized marijuana and cannabis based products for medical and/or recreational use, the US federal tax rules take a harsh perspective on the deductibility ...
Potential protective refund opportunity for US citizens impacted by repatriation tax
Our US citizen client base had been significantly and adversely impacted by the repatriation tax imposed on the retained earnings of their Canadian corporations. An opportunity may exist to file ...
Navigating the U.S. e-commerce state sales tax collection rules
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 ...