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U.S. Taxes Non-U.S. Corporation on Gross U.S. Business Income
The U.S. Tax Court issued an important decision in Adams Challenge (U.K.) Limited v. Commissioner (“Adams Challenge”) in January of 2021 that will have implications for Canadians conducting business in the U.S. This case adds an important insight regarding the scope of the non-discrimination provisions included in most U.S. tax treaties. The case provides a […]
Steven Flynn Featured on The Tax Chick Podcast
February 11, 2021Steven Flynn joins Amanda Doucette on The Tax Chick Podcast to talk about tax issues that arise for Canadians owning U.S. vacation property. Steven reviews the general rules for Canadians owning U.S. property and what you need to know if you are thinking about renting or selling your U.S. property this year. Listen to Where […]
Warren Dueck quoted in the Globe & Mail on consequences of tax residency for Canadian snowbirds
February 8, 2021Canadians who normally spend part of the year south of the border are having to deal with the cost of quarantining should they choose to return to Canada. However, if they decide to stay put, there are tax considerations. If the time they remain in the U.S. meets the “substantial presence test,” they may well […]
Global Intangible Low-Tax Income (GILTI) Explained
January 7, 2021In our latest YouTube video, Andersen partners Warren Dueck and Steven Flynn explain GILTI, a U.S. tax on the earnings of non-US corporations owned by U.S. investors. Warren and Steven cover how GILTI impacts U.S. persons, including those resident in Canada, who own Canadian and other non-U.S. corporations. They discuss why effective tax planning is […]