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U.S. Transition Tax – Update
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 HERE. This IRS guidance references earlier IRS updates and provides […]
U.S. Transition Tax
February 27, 2018In 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. tax. As part of this transition, many US shareholders are […]
U.S. Tax Reform – Getting Closer to the End
December 16, 2017Quite 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 a compromise on their different US tax bills. Details were […]
Canadian Tax – Federal Liberal Tax Changes on Private Corporations
September 22, 2017Over the last few months, much has been written about the proposed Canadian tax changes to private corporations. I am concerned about the speed at which the Department of Finance is moving to enact these significant and wide reaching tax changes. The proposals were introduced in the summer, while Parliament was not in session, and […]