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Form 8621 PFIC Reporting: Webinar with Steven Flynn

On Thursday, January 7, 2016, join Steven Flynn and a panel of cross-border tax specialists for a live webinar designed for tax advisers who deal with passive foreign investment company (PFIC) reporting. This program is eligible for 2.0 Continuing Professional Education credits and the learning objectives are described as follows: After completing this course, you […]

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Internal Revenue Service Amnesty Programs

November 17, 2015

In 2014, the IRS announced changes to its programs to help delinquent taxpayers file U.S. tax returns. We blogged about the changes to the Streamlined Foreign Offshore Procedures and Streamlined Domestic Offshore Procedures before; you can click to read our blog Internal Revenue Service Announces Changes to Streamlined Programs. The IRS has also created a […]

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Year End Planning – U.S. Citizens Who Own Canadian Mutual Funds

November 10, 2015

U.S. citizens living in Canada face adverse US income tax consequences where they own Canadian or other non-U.S. mutual funds. If you are not sure how the US’s “Passive Foreign Investment Company” rules apply here, please see our previous blog entry US Persons Holding Non-U.S. Mutual Funds. If you are familiar with this issue, then […]

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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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