Rechercher des blogs
Death and Taxes – U.S. Citizens Living in Canada
U.S. citizens who die while resident in Canada face taxation issues from two countries: Canadian income tax on unrealized gains and certain tax deferred assets and U.S. federal estate tax on the fair market value of all assets. This blog briefly summarizes the tax issues and offers some suggestions on how to minimize U.S. federal […]
American Same Sex Couples in Canada: Tax Effects of the Recent Supreme Court Decision in Windsor v. US
August 27, 2013On June 26, 2013, the US Supreme Court overturned Section 3 of the US Federal Defense of Marriage Act, more commonly known as “DOMA”. The effect of this decision is that the U.S. federal government is now required to recognize lawful same-sex marriages where the couple resides in a jurisdiction that recognizes that marriage. A […]
Mexican Land Trusts are Not Trusts for US Federal Income Tax Purposes
July 23, 2013In a recent Revenue Ruling, the IRS concluded that a fideicomiso or Mexican Land Trust (“MLT”) arrangement is not a trust for U.S. federal income tax purposes. This was welcome news to many U.S. citizens that own land located in Mexico through an MLT. As you may be aware from our previous blog entries, interests […]
Cross-border Gifts – Application of Article XIII – Gains
June 11, 2013Last month, we described a situation where a Canadian resident, nonresident alien of the US used the Canada – US Income Tax Convention (“Treaty”) to reduce their overall tax liability on employment income earned in the U.S. The second part of our Treaty example concerns the use of Article XIII to treat gains similar for […]
