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COVID-19 U.S. and Canadian Small Business Subsidies – A Comparison

Steven Flynn, CPA, CA, CPA (Washington) 04/06/2020

Canada and the U.S. recently created multiple financial assistance programs for businesses and individuals to address the economic challenges during the COVID-19 pandemic. Details continue to emerge in the beginning of April. We have been working with our clients who have business interests on both ...

Controlled Foreign Corporations Compliance

Final Regulations Partially Mitigate Overbroad Controlled Foreign Corporation Attribution Rules Passed as Part of 2017 U.S. Tax Reform

Andersen 01/28/2020

The U.S. Internal Revenue Service (“IRS”) recently finalized tax regulations under its complex controlled foreign corporation (“CFC”) regime that partially mitigate some of the harsh tax consequences resulting from an apparent drafting error contained in the 2017 U.S. tax reform legislation. The 2017 US tax ...

IRS Amnesty Programs Are Closing Soon. What You Need to Know.

Steven Flynn, CPA, CA, CPA (Washington) 01/23/2020

Explanation of IRS Amnesty Programs The Internal Revenue Service offers amnesty programs for individuals, corporations and other entities who fail to timely file certain U.S. federal income tax returns and forms pay applicable taxes. Participating in these programs allows taxpayers to correct delinquencies while minimizing ...

IRS Regulations Clarify 250A Deduction for Individual Owners of Non-U.S. Corporations Subject to GILTI

Andersen 03/05/2019

Last fall, we wrote about the U.S.’s Global Intangible Low Taxed Income (“GILTI”) and its’ adverse tax impact on U.S. persons that own non-U.S. corporations. GILTI impacts U.S. persons resident in Canada who own Canadian and other non-U.S. corporations. Without effective tax planning, combined U.S. ...

U.S. Transition Tax – Update Number Five

Steven Flynn, CPA, CA, CPA (Washington) 06/07/2018

As they did before the April 15th tax filing deadline, the IRS once again issued guidance on the U.S. transition tax right before a tax filing deadline. This time, the filing deadline is June 15, the extended filing deadline for U.S. taxpayers abroad, the very ...

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U.S. Transition Tax – Next Update

Steven Flynn, CPA, CA, CPA (Washington) 04/03/2018

On April 2nd, the IRS and U.S. Treasury issued more guidance on the U.S. Transition Tax enacted by the Tax Cuts and Jobs Act (“TCJA”) in December 2017. As the U.S. moves to a territorial tax system for profits earned outside the U.S., this provision ...

U.S. Transition Tax – Update

Steven Flynn, CPA, CA, CPA (Washington) 03/14/2018

On March 13th, the Internal Revenue Service provided further guidance on how U.S. taxpayers should report activity subject to the U.S. Transition Tax on their 2017 US income tax returns. Our previous blog describing the tax and its impact to U.S. taxpayers can be found ...

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

Steven Flynn, CPA, CA, CPA (Washington) 11/10/2015

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. ...

Now is the time for some year-end mutual fund and ETF planning!

Andersen 01/01/2015

If you are a U.S. citizen living abroad, you have undoubtedly heard about some of the U.S. tax issues and challenges associated with Canadian mutual funds and exchange traded funds (“ETFs”) which are generally considered to be “passive foreign investment companies” (“PFICs”). If you have ...

Internal Revenue Service Amnesty Programs

Steven Flynn, CPA, CA, CPA (Washington) 01/01/2014

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 ...

The member firms of Andersen in Canada focus on Canadian, international and Canada-U.S. cross-border tax matters. With offices across Canada, our tax professionals work with a broad range of businesses and individual clients to develop innovative tax solutions for a diverse range of issues. Our senior leaders and many of our professional staff have extensive experience in Canadian, international, U.S. and cross-border tax matters with major international accounting firms, as well as practical experience working with businesses and individuals.

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