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Internal Revenue Service Amnesty Programs
In 2014, the IRS announced changes to its programs to help delinquent taxpayers file U.S. tax returns. We blogged about the changes to the Streamlined Foreign Offshore Procedures and Streamlined Domestic Offshore Procedures before; you can click to read our blog Internal Revenue Service Announces Changes to Streamlined Programs. The IRS has also created a […]
Year End Planning – U.S. Citizens Who Own Canadian Mutual Funds
November 10, 2015U.S. citizens living in Canada face adverse US income tax consequences where they own Canadian or other non-U.S. mutual funds. If you are not sure how the US’s “Passive Foreign Investment Company” rules apply here, please see our previous blog entry US Persons Holding Non-U.S. Mutual Funds. If you are familiar with this issue, then […]
U.S. State and Local Tax Consideration for Canadian Businesses
September 1, 2015Often Canadian businesses are surprised to learn about the reach of U.S. state taxing jurisdictions to assert tax on out-of-state taxpayers. Since none of the 50 states were signatories to the Canada-U.S. Income Tax Convention (the “Treaty”), they are not limited by the Treaty to taxing business activities in the U.S. It is not uncommon […]
Canadian Tax Free Savings Accounts – U.S. Tax Treatment
August 25, 2015Canadian Tax-Free Savings Accounts (“TFSAs”) can be an excellent way to accumulate savings which will generally never be subject to Canadian income tax while they grow in value whether through investment income or gains. TFSAs have been around since 2009 and began with annual contribution limits of C$5,000. Beginning in 2015, the contribution limit increased […]