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Archive for International

Canada Tax Help – Learn About A Schedule 20

What is a schedule 20 as part of a T2 corporate tax return?

Schedule 20 is used to calculate an additional tax on non-resident corporations. This tax is called Part 14 or ‘branch’ tax and relates to non-resident corporations that earn income from a business carried on in Canada (see International FAQ #24) and have a permanent establishment in Canada (see FAQ #127). Read more

Converting Surplus Income Proposed Tax Changes (Canada)

 

The Canadian government is proposing tax changes to prevent private corporations from converting surplus income to a lower-taxed capital gain and stripping it from the corporation. This targets larger private corporations.

The Canadian tax system is built on the concept of tax integration. Based on the view of principles of fairness and neutrality, tax integration aims to ensure that an individual is indifferent between earning income through a corporation or directly as the after tax results should be the same.

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Stop Imposing Taxation On Residents Of Other Countries

Some of you may be interested in the “short letter” that I sent by regular mail to the “powers to be” in Washington who are working on “Tax Reform”.

A “Town Hall” interview with Speaker Ryan suggests that Tax Reform is going to happen. The question is whether individuals will also be considered. In January of 2017 Republicans Overseas proposed “territorial taxation” for individuals. This week the Republican National Committee adopted a resolution from Republicans Overseas urging that “territorial taxation” for individuals be adopted. Read more

Using Corporations To Reduce Or Defer Taxation For Individuals

The war against corporations and the shareholders of those corporations

Corporations as entities that are separate from their shareholder/owners

As every law students knows, a corporation is a legal entity that is separate from its owner. As a legal entity that is separate from its owner, a corporation is capable of holding assets, carrying on a business and investing in a way that results in separation of the shareholder(s) from the business itself. It is a mistake to infer that the corporation’s status as a separate legal entity means that the corporation’s income will not be taxed to its shareholders. Read more

Canadian Tax Help – Income Sprinkling Proposed Tax Changes

What are the proposed tax changes on sprinkling income using private corporations?

The Canadian government is proposing restrictions on income sprinkling to family members through dividends and capital gains. This targets private companies using shareholdings or a trust to split income among family members. Read more

New E-Business Visa Route For Frustrated Foreign Investors

Citizenship applications for the Caribbean island of Grenada have boomed in the last three years.

Reports have emerged that Grenada’s citizenship by investment program, introduced in 2014, is being used to fast-track U.S. E2 visa applications. Read more

What You Need To Know About Voluntary Disclosure

There are around 9 million Americans living oversees, and the IRS has its sights set on those expats who aren’t up to date with their U.S. tax filing.

All American citizens and green card holders are required to file a U.S. tax return, however because the U.S. is the only developed nation to tax its non-resident citizens, many haven’t realized that they have to file. Read more

Global Forum Publishes Ratings On Tax Transparency

The Global Forum on Transparency and Exchange of Information for Tax Purposes (the Global Forum) published the first 10 outcomes of a new and enhanced peer review process aimed at assessing compliance with international standards for the exchange of information on request between tax authorities.

The new round of peer reviews – launched in mid-2016 – follows a six-year process during which the Global Forum assessed the legal and regulatory framework for information exchange (Phase 1) as well as the actual practices and procedures (Phase 2) in 119 jurisdictions worldwide.

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Canadian Tax FAQs – Proposed Canadian Tax Changes

What are the proposed tax changes to private corporations that the Canadian government made in July 2017 and what do these changes mean for my company?

On July 18, 2017, the Canadian government proposed tax changes in an effort to remove tax advantages that small business owners have and address aggressive tax planning strategies involving the use of private corporations. These proposed changes are open for discussion until October 2, 2017, before being formally submitted for legislation. Read more

FTC v. Affordable Media: Foreign Asset Protection Trust Failures

Hale Stewart, Asset Protection

High net worth individuals are loathe to transfer assets to any entity over which they have no control. This fact creates an unresolvable problem when forming an offshore asset protection trust: so long as a U.S. person can exert even a modicum of control over a foreign entity, a U.S. court has sufficient grounds to rule that a U.S. based debtor can repatriate assets. More importantly, failure to comply with a repatriation order could lead to contempt citation against the U.S. debtor. The facts of Federal Trade Commission v. Affordable Media typify this problem. Read more

Canadian Tax FAQs – Difference Between GST And PST

How does PST (Provincial Sales Tax) work and how is it different from GST (Goods and Services Tax)?

PST is a provincially levied retail sales tax that is generally applied to goods or services acquired for personal use in British Columbia, unless there is a specific exemption. GST is a federally levied value added consumption tax that is applied to the supply of most of the goods and services purchased in Canada. Read more

The Biggest Cost Of Being A Dual Canada/U.S. Tax Filer

The reality of being a “DUAL” Canada U.S. tax filer is that you are a “DUEL” tax filer

“It’s not the taxes they take from you. It’s that the U.S. tax system leaves you with few opportunities for financial planning.”

I was recently asked “what exactly are the issues facing “Canada U.S. dual tax filers?” This is my attempt to condense this topic into a short answer. There are a number of “obvious issues facing U.S. citizens living in Canada.” There are a number of issues that are less obvious. Read more

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