Taxpayer Moved From Canada To The U.S. Has Problems With Canada Revenue Authority (CRA) Tax Notices

Phil Hogan - CRA Notices
Tax Question

I moved to the US from Canada 3 years ago and I’ve recently received some CRA tax notices that have been causing me problems. When I left in 2012 I neglected to tell my broker that I was moving. It wasn’t until the next year that I realized (because he told me) that I should have turned my account into a non-resident account and taxes should have been withheld and sent to CRA on my dividends.

After many months of going back and forth with CRA I managed to get the tax withholdings resolved. However now I have a different problem. I’ve also paid US tax on these dividends and now I have CRA notices telling me that I also have to pay tax on the same dividends. From my calculations I’m paying about 10% US tax and 15% Canadian tax on these dividends. Should I really be paying 25% total on dividends from Canada?

I tried to get some help from my US CPA but he keeps telling me that there’s nothing I can do and to just pay the CRA bill.

Is this really my only option? They also continue to withhold the 15% tax. Am I stuck with 25% tax. If so, should I move these investments to the US?

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IRS Rules: How Long Should You Keep Your Tax Records

IRS - Records Retention Rules

The length of time you should keep a document depends on the action, expense, or event which the document records. Generally, you must keep your records that support an item of income, deduction or credit shown on your tax return until the period of limitations for that tax return runs out.

The period of limitations is the period of time in which you can amend your tax return to claim a credit or refund, or the IRS can assess additional tax. The information below reflects the periods of limitations that apply to income tax returns. Unless otherwise stated, the years refer to the period after the return was filed. Returns filed before the due date are treated as filed on the due date.

Note: Keep copies of your filed tax returns. They help in preparing future tax returns and making computations if you file an amended return.

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International Tax Partner – Multinational Law Firm (Midwest)

International Tax Partner Job - Law Firm

TaxConnections has been retained by a leading multinational law firm to locate a Tax Partner to lead the Midwest region in serving  international clients. This market facing role is due to the continued expansion of the international and transfer pricing practice. The Tax Partner will team with a group of talented economists who are already in place to grow the Midwest tax practice. The law firm currently has about 80 tax lawyers worldwide and this successful practice is expected to double in size over the next five years.

Our client is happy to talk to Senior Tax Managers, Managing Directors or Principals who currently do not hold a Tax Partner title.

The Tax Partner will assist multinational clients to design, develop, implement, document and defend transfer pricing strategies. They will provide clients guidance in analyzing factual material, communicate the benefits of the transfer pricing methodologies both to government representatives and the courts and negotiate advance pricing agreements on a worldwide basis.

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Tax Professionals Wanted:  Positioning For Virtual Tax Jobs

Kat Jennings - Become A TaxConections Member

Two years ago, we were contacted by a company who wanted to hire 3000 tax professionals on a seasonal basis. The company was challenged to find tax talent and so they came to us. What is important to understand is that they needed to find a better way to hire a remote online tax workforce, so they came to us for one. There are a lot of changes occurring in the tax marketplace right now. How do you get noticed by companies who are searching for your tax expertise? How do you access the growing trend in the virtual or remote tax workforce? It is all about positioning yourself in a way that makes it easy to find you and your tax expertise online. Even if you are not searching for a tax job you need to work smart and position your tax expertise online today.

Most tax professionals are hidden behind pay walls or multiple click barriers and are not easily found. How do I know these barriers exist? As a highly trained tax executive search expert, I know the obstacles and challenges more intimately than most anyone out there since I live and breathe tax professional search. What I see now are payment barriers set up all over the internet that prevent others from ever connecting with you in the first place. You are blocked by barriers and most of you are simply unaware of these obstacles to your success. Your name and reputation may be at the back pages of search engines (never to be discovered) or the front pages of sites who now request a payment upgrade before anyone can connect with you. These barriers are costing you dearly many tax opportunities and clients.

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New York State Boards The Wayfair Train

Monika Miles - New York State Boards The Wayfair Train

In the United States, the sales tax landscape has changed dramatically due to the recent U.S. Supreme Court Case of South Dakota v. Wayfair (June 2018). Following this landmark decision which made it easier for companies to create nexus in states, many states have enacted legislation which create guidelines/thresholds for economic nexus. In a previous blog, we talked about this epic decision. Through December, over 30 states had enacted economic nexus legislation. But we had not heard from New York.

What Is Economic Nexus?

Prior to the Wayfair decision, companies needed to have physical presence, or “boots on the ground,” in a state in order to have nexus (or taxable presence) in a state. This meant that a company had to have offices, inventory, employees, or contractors in a state for a certain amount of time. Companies now don’t necessarily need to have physical presence in a state for them to create nexus; they now can have nexus in a state by virtue of economic nexus. Economic nexus means that if companies have sales of a certain dollar amount or have a certain number of transactions with a state, the state can require the company to register, collect and remit sales tax.

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Success Story: The Taxpayer Advocate Service Protects Taxpayers’ Rights In IRS Tax Lien Case

Nina Olson- Need Help From The Taxpayer Advocate Service

Every year, the Taxpayer Advocate Service (TAS) helps thousands of people with tax problems. This story is only one of many examples of how TAS helps resolve taxpayer’s tax issues. All personal details are removed to protect the taxpayer’s privacy.

TAS is an advocate for protecting taxpayers’ rights. This success story is an example of how TAS’s advocacy protected a taxpayer’s fundamental Right to a Fair and Just Tax System by negotiating with the IRS to withdraw a tax lien.

A taxpayer had an IRS balance due, but paid the tax bill. After the taxpayer paid the IRS balance, the IRS filed a Notice of Federal Tax Lien which jeopardized the taxpayer’s employment. Although the IRS released the lien, it remained a matter of public record. The IRS refused to withdraw the lien even though the IRS filed it after the taxpayer paid the balance in full. TAS got involved and negotiated with the IRS on behalf of the taxpayer to successfully obtain a lien withdrawal.

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Crowdfunding And Taxes: What You Need To Know

Jim Marshall - Crowdfunding And Taxes

In recent years, raising money online through third-party backers, or crowdfunding, has grown in popularity.  Originally utilized mostly by musicians, filmmakers and for other creative endeavors, it has now become a more widespread method of raising money for a trip, medical expense, or startup, and is often a quicker and easier alternative than conventional fundraising.  Often the creator of a campaign puts little thought to the tax ramifications before launching and collecting the funds.  With this increase in utilization, the business of its taxation has become an increasing question.  While Congress and the IRS have not addressed crowdfunding income specifically, applying standard tax principles and common sense may help when talking through the issues surrounding taxable crowdfunding income and deciding how to report and pay taxes on it.

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Senior Vice President Tax – M&A, Real Estate (Southern California)

Senior Vice President Tax - Real Estate And Mergers And Acquisitions

TaxConnections has been retained to conduct a search for a Senior Vice President Tax for a Southern California client. This tax executive role requires a high level of executive presence and interface with a wide range of internal and external advisors.  Responsibilities include private equity and real estate deals, mergers and acquisitions, financial modeling; review corporate and partnership tax returns; and managing company’s income tax compliance activities  (insourced and  outsourced); advise senior management regarding tax liabilities; and supervision of the incumbent tax team.

The Senior Vice President of Tax will lead acquisition structuring and due diligence including tax integration efforts including:

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Global Tax Revenue Authorities – Free Gift From TaxConnections

Kat Jennings - Tax Revenue Authorities Free Gift

As part of the many resources available through TaxConnections, we have created a list of 250+ Global Tax Authorities Country Representatives contact information including names, emails and revenue authority sites. This valuable resource is ideal for tax professionals who want access to save time locating global tax revenue authority contact information.

We developed a resource of 250 identifying tax revenue authorities in more than 150 countries.

Make a request to receive a complimentary pdf copy at this link: .

TaxConnections Members  can view the monthly updates in their virtual tax offices.



Tax Cuts and Jobs Act: What Is New For Small And Medium Sized Businesses

IRS - What Is New In Tax Cuts And Jobs Act For Small And Medium Sized Businesses

Congress approved major tax reform in the Tax Cuts and Jobs Act, signed into law on December 22, 2017. This legislation, which affects both individuals and businesses, is commonly referred to as TCJA or the 2017 tax reform legislation. This electronic publication covers many of the TCJA provisions that are important for small and medium-sized businesses, their owners and tax professionals to understand. Businesses affected by TCJA include corporations, S corporations, partnerships (including limited liability companies or LLCs) and sole proprietorships. Changes to deductions, depreciation, expensing, credits, fringe benefits and other items may affect your business tax liability and your bottom line.

It’s important to consider your business structure and accounting methods when applying tax reform to your situation. The official website includes a Tax Reform page that highlights what you need to know about the tax law changes. This page also provides links to news releases, publications, notices, legal guidance and other resources. There’s also a dedicated tax reform page for businesses. We update these resources regularly. Some provisions of TCJA that affect individual taxpayers can also affect business taxes. As a business owner or self-employed individual, you should review tax reform changes for individuals and determine how these provisions affect your business tax situation.

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As IRS Develops “Future State” Plan To Assist Taxpayers Digitally – Free Problem Solving Help Available For Taxpayers At Specific Locations

Nina Olson- Future State Plans

The Taxpayer Advocate Service (TAS) will conduct Problem Solving Day events in communities throughout the country in the coming months and year. During these events, TAS employees from a local office will be available to assist taxpayers in person with tax problems they have not been able to resolve with the IRS. Generally, TAS can assist taxpayers whose problems with the IRS are causing financial difficulties, who’ve tried but haven’t been able to resolve their problems with the IRS, or believe an IRS system or procedure isn’t working as it should. And our service is free.

Why Is TAS Holding Problem Solving Days?

Congress created the Office of the National Taxpayer Advocate as we know it today through the IRS Restructuring and Reform Act of 1998 (RRA 98). The law further strengthened the role of TAS and provided for Local Taxpayer Advocates in each state. TAS maintains a geographic presence in each state, the District of Columbia, and Puerto Rico, and continues to look at changing taxpayer demographics to adjust its footprint to meet taxpayer needs. Recognizing the importance of personal contact, we work one-on-one with taxpayers and their representatives within our area to resolve their tax issues.

As the IRS develops its “Future State” plan that focuses on assisting taxpayers digitally rather than in person, the National Taxpayer Advocate continues to elevate her concerns about the plan through her Reports to Congress.

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Senior Vice President Tax – Large Family Office (Los Angeles, CA)

Senior Vice President Tax - Large Family Office

TaxConnections has been retained to conduct a search for a tax executive for a private equity, family office in Los Angeles, CA.

This is an opportunity for a Tax Partner in a Big Four firm or Law Firm to move into a large family office focused on multiple transactions.

Responsibilities include financial modeling, global tax strategy, tax planning and compliance; review the filing of all domestic and international corporate, personal, partnership and other income and indirect tax returns; and implementing and managing company’s income tax and indirect tax compliance activities (partially insourced and partially outsourced); advise senior management regarding the impact and tax liabilities; and supervision of an outstanding, incumbent tax team.

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