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

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. ...
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US Transition Tax

U.S. Transition Tax – Next Update

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 ...
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US Transition Tax

U.S. Transition Tax

02/27/2018
In December 2017, the U.S. enacted The Tax Cuts and Jobs Act (“TCJA”). Amongst many changes to U.S. tax law is a move to a territorial tax system where US corporate shareholders of non-U.S. corporations can repatriate profits earned outside the U.S. without additional U.S. ...
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U.S. Tax Reform – Getting Closer to the End

12/16/2017
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 ...
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Andersen Expertise

Is the interest expense deductible for US non-resident aliens owning a U.S. real property interest?

11/29/2017
Loaning 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 ...
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Trump’s Tax Plans

11/10/2016
Donald Trump’s surprise election win has people wondering about his tax plans. Many things said on the campaign trail never result in any change. To achieve any of his tax plans, Trump will need the cooperation of Congress, including those he likely alienated, if not ...
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US Tax vs. Canadian Tax

12/03/2012
There are many similarities between the U.S. and Canada, but there are some significant distinctions between U.S. and Canadian tax law especially for U.S. citizens resident in Canada, including permanent residents of the US (“green-card” holders). For the unwary those distinctions may result in substantial ...
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US Persons Holding Non-U.S. Mutual Funds

11/20/2012
U.S. citizens and lawful permanent residents (green card holders) who hold certain investments may unknowingly be subject to adverse US tax implications where the investments are characterized as investments in Passive Foreign Investment Companies (“PFICs”). PFICs include non-U.S. mutual funds and exchange traded funds (ETFs) ...
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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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