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Archive for International

Participating vs Non-Participating Shares – Canada Tax FAQs

Why should I be concerned about participating and non-participating shares in my company?

Shares in a corporation can be participating or non-participating, among other features. Participating shares are eligible to “participate” in the equity growth of the company and be permitted to receive dividends. Non-participating shares do not benefit from the equity growth of the company. This can potentially impact the valuation of shares. Read more

Greek Co. Not Liable For Gain From Sale Of Partnership Interest

Ron Marini

The Tax Court has concluded that a foreign corporation’s proceeds from the redemption of a U.S. limited liability company that was treated as a partnership for U.S. income tax purposes was not U.S.-source income and was not effectively connected with a U.S. trade or business. Read more

Class 10 vs 10.1 Assets – Canadian Tax FAQs

How do I determine if my new vehicle is a Class 10 or Class 10.1 asset and what are the tax implications?

Any vehicle with a purchase cost of over $30,000 can be classed as a luxury vehicle (a 10.1 asset). This classification restricts the amount of depreciation that can be deducted from income which reduces your corporate expenses and increases your corporate tax. It also limits the amount of GST that can be recovered. The determining factor is whether the vehicle is a passenger vehicle or a motor vehicle by CRA’s definitions. Read more

Exactly What Income Can U.S. Expats Exclude? FEIE

American expats are, unfortunately, still required to file U.S. taxes from abroad. Thankfully though, there are several exclusions that reduce or in most cases eliminate their U.S. tax liability. The foremost among these is the Foreign Earned Income Exclusion. Not owing U.S. taxes doesn’t exempt expats from having to file a U.S. tax return though, as the exclusions that reduce or eliminate U.S. tax liability for expats must be claimed each year when expats file their federal return. Read more

Do Tax Preparers Know If Non-US Mutual Funds Are PFIC?

John Richardson

I have written many posts that include a discussion of PFICs. This post has been motivated by a post by Karen Alpert at “Fix The Tax Treaty” (well it can’t really be fixed). The post focuses on the use of “non-U.S. mutual funds” in retirement planning. The post is written from the perspective that “non-U.S. mutual funds” ARE PFICs. Read more

American Expatriates In London – Tax Info You Need

Hugo Lesser

American expats living in London find themselves in the unenviable position of having to file both U.S. taxes as a U.S. citizen, and UK taxes as a UK resident, on their worldwide income.American expats living in London find themselves in the unenviable position of having to file both U.S. taxes as a U.S. citizen, and UK taxes as a UK resident, on their worldwide income.

To complicate things further, the UK tax year runs from April 6th to April 5th, rather than being the calendar year. Read more

Roth IRA Taxation For Expats In Canada

The importance of income tax treaties should not be underestimated when considering the U.S. tax implications of living abroad. U.S. and foreign tax laws often fall short of ensuring that U.S. expats are on equal tax footing with their non-expat counterparts. In such case, a relevant tax treaty may be available to pick up the slack. Read more

Understanding The T106 Information Return – Canadian Tax

Grant Gilmour

What is a T106 information return of non-arm’s length transactions with non-residents?

Facts:

A T106 is an annual information return where a corporation reports its non-arm’s length activities with non-residents. Non-arm’s length transactions are generally transactions where the parties are considered to be related. Read more

Cuba Embargo Re-Imposed: What It Means For Your Assets

How will OFAC implement the changes to the Cuba sanctions program announced by the President on June 16, 2017? Are the changes effective immediately?

OFAC will implement the Treasury-specific changes via amendments to its Cuban Assets Control Regulations. The Department of Commerce will implement any necessary changes via amendments to its Export Administration Regulations. OFAC expects to issue its regulatory amendments in the coming months. The announced changes do not take effect until the new regulations are issued. Read more

Estate Planning For American Expatriates

Retiring abroad is more popular than ever, thanks to perceptions of a better quality of life, more affordable health care, and a warmer climate.

Americans living abroad earning over $10,000 a year (or just $400 of self-employment income) are still required to file a U.S. tax return though, declaring their world wide income. This includes expats who have retired or settled permanently abroad. Read more

It’s All Greek To Me!- Multistate Tax & Foreign Companies

I just returned from an amazing vacation – a cruise of the Mediterranean. We started in Athens, Greece; spent just a couple days there enjoying the history, and then boarded our ship.  The cruise took us to the Greek isles of Santorini and Crete, and then we sailed to Italy, the beautiful St. Tropez, France, and finally Barcelona, Spain. We finished our vacation by sampling many, many tapas and wines in Barcelona. About midway through our vacation, I found myself wondering – how could I do U.S. multistate tax consulting somewhere in Europe?  I’m still working on that angle, and will certainly keep you posted. Read more

Beneficial Ownership Register Starting July 1st

Ron Marini

The British Virgin Islands’ Government signed new legislation regarding Beneficial Ownership & Technical Protocol with the UK which will come into force in June 2017, which is hoped to improve the exchange of beneficial ownership information between the UK& BVI law enforcement for taxation rulings. Read more

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