Rechercher des blogs
Mexican Land Trusts are Not Trusts for US Federal Income Tax Purposes
In 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 […]
Canada U.S. Tax Treaty – US Nonresident Alien Using “Married Filing Joint” Tax Rates
May 17, 2013Two recent client situations remind us that certain provisions in the Canada US Income Tax Convention (“Treaty”) can lower a client’s overall tax liability even where the answer isn’t so obvious when entering information in tax software. The first example is the subject of today’s blog. The second example will be posted later this month. […]