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The Application of the US PFIC Regime to Canadian Startups

The Application of the US PFIC Regime to Canadian Startups

by Polaris Tax Counsel | Apr 12, 2017 | Technical Articles

In the latest issue of Tax Topics from Wolters Kluwer, Max Reed explains the ramifications of US passive foreign investment company polices to Canadian startups and their investors. Read the full piece here.

The Application of the US PFIC Regime to Canadian Start-Ups

by Polaris Tax Counsel | Mar 31, 2017 | Cross-Border Tax

Many Canadian start-ups, whether junior mining, biotech, or tech, receive funding from investors in the United States (or from US taxpayers who reside in Canada). If the proper steps are not taken, a punitive US tax regime (the passive foreign investment company or...
US Government sues Canadian resident US citizen for 860K in penalties

US Government sues Canadian resident US citizen for 860K in penalties

by Polaris Tax Counsel | Mar 10, 2017 | Cross-Border Tax

Last May, the U.S. Department of Justice sued Jeffrey P. Pomerantz — a Canadian resident, US citizen — for over USD $860,300 in penalties and interest for failing to file his FBAR bank disclosure forms. This case is one of the first known instances of the...

Can Clients Ditch U.S. Citizenship Retroactively?

by Polaris Tax Counsel | Oct 19, 2016 | Cross-Border Tax

Whether for ideological reasons or tax complications, many people want to shed their U.S. citizenship. There are two ways to do so: renunciation and relinquishment.  Renunciation requires swearing an oath at a U.S. consulate. A person who renounces is no longer a U.S....

The Tax Consequences of Inheriting Money from the U.S.

by Polaris Tax Counsel | Oct 19, 2016 | Cross-Border Tax

Many Canadians inherit money from relatives in the United States. There are generally no issues on either side of the border if a Canadian inherits property or money through a will. That being said, many U.S. residents plan their estates by using a trust rather than a...
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Questions?

If you’re looking for more clarity in your cross-border tax situation, contact Max Reed at
+1-604-283-9301 or via email at max@polaristax.com to find out how we can help you.

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