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Publications by Date

US Filing Obligations of Non-residents of the US

There has been a lot of attention in the media about U.S. citizens who live in Canada and their U.S. tax filing obligations. Non-U.S. citizens who are not resident in the U.S. (“NRA” for non-resident aliens) may also have U.S. tax filing obligations where they ...
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Canadian Business Investment in the US

The US is a natural market for Canadian businesses. While there are many similarities between doing business in Canada and the U.S., it is the differences that require your attention. Canadian corporate tax rates are about a third lower than their equivalent in the U.S., ...
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Consulting in the U.S. – Planning in advance well worth it

Independent consultants in Canada will often incorporate their practice in order to offer some liability protection not otherwise achieved through a sole-proprietorship structure. From a Canadian income tax perspective, the incorporated consultant will often make the choice between compensating himself by way of salary or ...
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Online Poker Winnings – Taxable in Canada or the U.S.?

A recent Canadian tax court case confirmed that an online poker player’s winnings were not subject to Canadian income tax. In Radonjic V. The Queen, 2013 FCC 916, Peter Radonjic, a Coquitlam BC resident, paused his career as a lawyer to play online poker on ...
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Repaying your Canadian-dollar mortgage? Don’t be surprised by a US tax bill.

The ownership of real property is often made possible with mortgage and other debt financing. Such mortgage financing offers a U.S. taxpayer the ability to deduct for income tax purposes the interest paid, subject to some limitations. The repayment of the mortgage would not normally ...
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Canada-United States Social Security Agreement

An often overlooked agreement between the two countries can result in significant savings for Canadians moving to the United States. The Canada-United States Social Security Agreement (“Agreement”) provides direction to individuals on which country levies social security taxes, allows for continuation of benefits and coverage ...
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2013 Changes to the US Individual Taxpayer Identification Number ID requirements

Have you earned income from the U.S., or perhaps sold a personal property in 2013? If so, there is a very good chance you will need to file a US income tax return. In order to do so, you will be required to obtain either ...
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Death and Taxes – U.S. Citizens Living in Canada

U.S. citizens who die while resident in Canada face taxation issues from two countries: Canadian income tax on unrealized gains and certain tax deferred assets and U.S. federal estate tax on the fair market value of all assets. This blog briefly summarizes the tax issues ...
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Mexican Land Trusts are Not Trusts for US Federal Income Tax Purposes

In a recent Revenue Ruling, the IRS concluded that a fideicomiso or Mexican Land Trust (“MLT”) arrangement is not a trust for U.S. federal income tax purposes. This was welcome news to many U.S. citizens that own land located in Mexico through an MLT. As ...
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Cross-border Gifts – Application of Article XIII – Gains

Last month, we described a situation where a Canadian resident, nonresident alien of the US used the Canada – US Income Tax Convention (“Treaty”) to reduce their overall tax liability on employment income earned in the U.S. The second part of our Treaty example concerns ...
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The member firms of Andersen in Canada focus on Canadian, international and Canada-U.S. cross-border tax matters. With offices across Canada, our tax professionals work with a broad range of businesses and individual clients to develop innovative tax solutions for a diverse range of issues. Our senior leaders and many of our professional staff have extensive experience in Canadian, international, U.S. and cross-border tax matters with major international accounting firms, as well as practical experience working with businesses and individuals.