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U.S. Taxes Non-U.S. Corporation on Gross U.S. Business Income

The U.S. Tax Court issued an important decision in Adams Challenge (U.K.) Limited v. Commissioner (“Adams Challenge”) in January of 2021 that will have implications for Canadians conducting business in the U.S. This case adds an important insight regarding the scope of the non-discrimination provisions included in most U.S. tax treaties. The case provides a […]

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U.S. Federal Corporate Income Tax and Canadian Businesses Operating in the United States. What You Need to Know.

June 17, 2020

In our latest video, Andersen partner Steven Flynn provides insights on the impact of U.S. federal corporate income tax for Canadian businesses operating in the United States. The video illustrates that there is now more flexibility for Canadian businesses seeking to do business in the U.S. and that Canadian companies can optimize their tax positions […]

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U.S. State and Local Tax Consideration for Canadian Businesses

September 1, 2015

Often Canadian businesses are surprised to learn about the reach of U.S. state taxing jurisdictions to assert tax on out-of-state taxpayers. Since none of the 50 states were signatories to the Canada-U.S. Income Tax Convention (the “Treaty”), they are not limited by the Treaty to taxing business activities in the U.S. It is not uncommon […]

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