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Blog Alert – Repatriating U.S. Earnings to Canada

Repatriating corporate earnings from the U.S. to Canada may involve alternative strategies. These include using U.S. earnings to repay debts payable to its Canadian shareholder, management fees, dividends, and liquidating distributions. Let’s explore the key aspects and considerations when repatriating U.S. earnings to Canada. Debt Repayment In general, the repayment of debts including interest incurs […]

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U.S. Transition Tax – A Fourth Update

April 14, 2018

In mid-April, there is usually a race against time by taxpayers and accountants to meet U.S. tax filing deadlines. The normal U.S. tax filing deadline for the 2017 year for individuals and certain U.S. entities is Tuesday, April 17th (a few days later than the usual April 15th due to weekends and a U.S. holiday […]

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U.S. Transition Tax – Next Update

April 3, 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 assesses a tax rate on accumulated earnings and profits in […]

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U.S. Transition Tax

February 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. tax. As part of this transition, many US shareholders are […]

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