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U.S. Tax Reform – Getting Closer to the End
Quite the week for tax professionals in Canada and the U.S. On Wednesday, Finance Minister Bill Morneau provided guidance on how Canada’s income splitting rules will apply to private corporations. You can read more about it here: https://www.canada.ca/en/revenue-agency/programs/about-canada-revenue-agency-cra/federal-government-budgets/income-sprinkling.html On Friday, the House and Senate reached a compromise on their different US tax bills. Details were […]
Is the interest expense deductible for US non-resident aliens owning a U.S. real property interest?
November 29, 2017Loaning between business entities is a widely-adopted business strategy in the real estate industry. Multiple levels of entities are often chosen in a business structure. U.S. limited liability companies (“LLC”) are commonly used to hold U.S. real property interests. When foreign investors are involved for various reasons (i.e., asset protection), foreign investors use a non-U.S. […]
Outbound Issues – Ownership of Non-U.S. Corporations Subpart F Income
October 17, 20173 Day Tax Conference November 15 – 17, 2017 – Burbank, CA Join Steven Flynn, a partner with W.L. Dueck & Co. LLP at an upcoming CalCPA Tax Conference in Burbank, Los Angeles on November 15 – 17. During this Federal, State, Local & International Taxation Conference, Steven will bring expertise on Outbound Issues, Ownership […]
Tax Planning Using Private Corporations – July 18, 2017 Paper (“Paper”) Request for Comments
October 2, 2017Department of Finance Canada Via email: fin.consultation.fin@canada.ca RE: Tax Planning Using Private Corporations – July 18, 2017 Paper (“Paper”) Request for Comments Dear Recipients: We have read the Paper, reviewed many articles and discussed with and listened to our clients, colleagues and others in our community. We have concerns with the proposed changes in their […]