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US Gift Tax Exposure on Joint Ownership of Property
The most common way spouses hold property in Canada is joint tenancy with right of survivorship. Joint ownership provides each joint tenant an undivided interest in the property and when one spouse dies, the property immediately passes to the surviving spouse without probate. In the case where one spouse is a U.S. citizen and the […]
Low Risk U.S. Tax Compliance
January 4, 2013On June 26, 2012 the Internal Revenue Service (“IRS”) announced new streamlined filing procedures (“SFP”) for non-resident U.S. taxpayers to go into effect September 1, 2012. SFP is available to U.S. persons and dual citizens living outside the US who have failed to timely file U.S. federal income tax returns or disclose their non-U.S. bank […]
US Tax vs. Canadian Tax
December 3, 2012There 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 U.S. tax liabilities where those differences are not identified in […]
US Persons Holding Non-U.S. Mutual Funds
November 20, 2012U.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) which are typically organized as corporations or trusts in Canada. […]