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IRS Regulations Clarify 250A Deduction for Individual Owners of Non-U.S. Corporations Subject to GILTI

Last fall, we wrote about the U.S.’s Global Intangible Low Taxed Income (“GILTI”) and its’ adverse tax impact on U.S. persons that own non-U.S. corporations. GILTI impacts U.S. persons resident in Canada who own Canadian and other non-U.S. corporations. Without effective tax planning, combined U.S. and Canadian tax rates approaching 85% could occur as early […]

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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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U.S. Tax Reform – Getting Closer to the End

December 16, 2017

Quite 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 […]

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