by Polaris Tax Counsel | Mar 8, 2024 | Cross-Border Tax, News
NHL player John Tavares’ well-publicized litigation pending before the Tax Court of Canada demonstrates the principle that resolving cross-border tax disputes in a purely domestic fashion can be problematic. The facts of the case are straightforward and worth...
by Polaris Tax Counsel | Oct 24, 2023 | Cross-Border Tax, News
For many US citizens who are resident in Canada, the Net Investment Income Tax (NIIT) is the only US tax they pay every year. Without a foreign tax credit or exemption, the imposition of the NIIT results in double taxation since the investment income is also subject...
by Polaris Tax Counsel | Aug 14, 2022 | Cross-Border Tax, News
Prepared by Max Reed, Polaris Tax Counsel and Tim Barrett, Thorsteinssons LLP In the April 2022 federal budget, the Canadian government proposed significant changes to the Canadian international tax rules (specifically the “foreign accrual property income” or “FAPI”...
by Polaris Tax Counsel | Sep 8, 2021 | Cross-Border Tax
The limited liability company (“LLC”) is a very common US business entity that unfortunately can cause Canadian tax problems for its owners. These problems primarily arise from a fundamental difference in how many LLCs are taxed in the US and Canada. For a Canadian...
by Polaris Tax Counsel | Jan 12, 2021 | Cross-Border Tax, News
The resolution of three recent cases at the IRS Independent Office of Appeals support our longstanding view that no Form 3520 or 3520-A are required to report a TFSA to the IRS. As background, last year the IRS released guidance that exempted taxpayers from filing...
by Polaris Tax Counsel | Apr 27, 2020 | Cross-Border Tax
In the previous installment, we discussed the potential Canadian tax problems when a Canadian tax resident purchases a US life insurance policy. In this installment, we examine the same scenario in reverse – what happens when a US taxpayer purchases a Canadian life...
