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900,000 Canadian Bank Records Were Recently Sent to the IRS – What you Need to Know

Warren Dueck, FCPA, FCA, CPA (Washington) 11/15/2019

A new CBC article notes that the Canadian government sent a significant trove of records to U.S. tax authority, the Internal Revenue Service in September of 2019 in accordance with a “controversial information-sharing deal” and that the quantity of records involved represents a sharp increase ...

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. ...

Global Intangible Low-Taxed Income (“GILTI”)

Andersen 10/09/2018

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 ...

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