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Renouncing US Citizenship After US Tax Reform
The new U.S. tax rules are likely to increase the number of Canadian resident US citizens who want to renounce. US tax reform did not change the rules around renunciation very much, but it did expand the category of people who are able to renounce U.S. citizenship...
Pleading Not GILTI – Deferral Strategies for Canadian-Resident US Citizens
A recently passed US tax law makes it more complicated for American citizens outside the United States to run businesses, because their income may be “GILTI”. GILTI is an acronym for “Global Intangible Low-Taxed Income”. Under the new US corporate tax system, US...
New US Tax Rules will Encourage Americans Abroad to Renounce
The newly passed US tax law (the Tax Cuts and Jobs Act (“TJCA”)) makes it much more complex for American citizens outside the United States to run a business. Specifically, there are two new complex tax regimes to consider: 1) the one-time mandatory repatriation tax...
The Grind down of Foreign Tax Credits and the Code Section 965 Inclusion
This blog post addresses a very technical question about the new US repatriation tax. It will only be of interest to US tax advisors. It is not meant as legal advice and cannot be relied upon as such. It involves complex US tax concepts so advice specific to the...
Code Section 965 and Individual Taxpayers – a technical explanation
This blog post addresses a very technical question about the new US repatriation tax. It will only be of interest to US tax advisors. It is not meant as legal advice and cannot be relied upon as such. It involves complex US tax concepts so advice specific to the...
The new US “one-time tax” on US citizens who own foreign corporations
The United States is in the throes of the most comprehensive tax reform since 1986. On November 16, the House passed its version of the Tax Cuts and Jobs Act ("TCJA"). The Senate passed its version on December 2. While there are significant differences, both versions...
US Tax Reform Presents Opportunities for Canadian Businesses
On November 2, 2017, the US House of Representatives unveiled the Tax Cuts and Jobs Act which contains the most sweeping changes to US tax law in 30 years. While it remains unclear whether, when, or in what form the new bill will become law, but if it passes in its...
Impact of New US Tax Law on US Citizens in Canada
On November 2, 2017, the House of Representatives unveiled the most sweeping reforms to US tax law in 30 years. If passed, it will make matters worse for some US citizens in Canada and keep it the same for others. Some key implications include: No elimination of...
The Application of the US PFIC Regime to Canadian Start-Ups
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
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...