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U.S. Transition Tax – Next Update
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 […]
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 […]
Is the interest expense deductible for US non-resident aliens owning a U.S. real property interest?
November 29, 2017Loaning between business entities is a widely-adopted business strategy in the real estate industry. Multiple levels of entities are often chosen in a business structure. U.S. limited liability companies (“LLC”) are commonly used to hold U.S. real property interests. When foreign investors are involved for various reasons (i.e., asset protection), foreign investors use a non-U.S. […]
