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Death and Taxes – U.S. Citizens Living in Canada
U.S. citizens who die while resident in Canada face taxation issues from two countries: Canadian income tax on unrealized gains and certain tax deferred assets and U.S. federal estate tax on the fair market value of all assets. This blog briefly summarizes the tax issues and offers some suggestions on how to minimize U.S. federal […]
Mexican Land Trusts are Not Trusts for US Federal Income Tax Purposes
July 23, 2013In a recent Revenue Ruling, the IRS concluded that a fideicomiso or Mexican Land Trust (“MLT”) arrangement is not a trust for U.S. federal income tax purposes. This was welcome news to many U.S. citizens that own land located in Mexico through an MLT. As you may be aware from our previous blog entries, interests […]
Cross-border Gifts – Application of Article XIII – Gains
June 11, 2013Last month, we described a situation where a Canadian resident, nonresident alien of the US used the Canada – US Income Tax Convention (“Treaty”) to reduce their overall tax liability on employment income earned in the U.S. The second part of our Treaty example concerns the use of Article XIII to treat gains similar for […]
Don’t forget about State and Local income tax implications when working in the US!
June 7, 2013The domestic tax implications of living and working in one country are generally straight-forward. While there may be from time to time some complicating domestic tax issues, generally, with a bit of resourcefulness you don’t need to be a tax specialist to resolve the personal tax matter (although you may like to hand it off […]