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American Same Sex Couples in Canada: Tax Effects of the Recent Supreme Court Decision in Windsor v. US

On June 26, 2013, the US Supreme Court overturned Section 3 of the US Federal Defense of Marriage Act, more commonly known as “DOMA”. The effect of this decision is that the U.S. federal government is now required to recognize lawful same-sex marriages where the couple resides in a jurisdiction that recognizes that marriage. A […]

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Mexican Land Trusts are Not Trusts for US Federal Income Tax Purposes

July 23, 2013

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 you may be aware from our previous blog entries, interests […]

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Cross-border Gifts – Application of Article XIII – Gains

June 11, 2013

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 the use of Article XIII to treat gains similar for […]

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Don’t forget about State and Local income tax implications when working in the US!

June 7, 2013

The domestic tax implications of living and working in one country are generally straight-forward. While there may be from time to time some complicating domestic tax issues, generally, with a bit of resourcefulness you don’t need to be a tax specialist to resolve the personal tax matter (although you may like to hand it off […]

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