The December 2017 U.S. tax reform included a provision to subject to U.S. tax the earnings of intellectual property owned by U.S. investors outside the U.S. GILTI impacts U.S. persons resident in Canada who own Canadian and other non-U.S. corporations. Without effective tax planning, combined U.S. and Canadian tax rates approaching 85% could occur as […]

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 […]