An Update on the NIIT Foreign Tax Credit

In an article published on October 24, 2023, we canvassed the unsettled landscape for Canadian-resident US citizens to claim foreign tax credit against their US Net Investment Income Tax (the “NIIT”) under the U.S.-Canada Treaty (the “Canada Treaty”). There have been...

US LLCs Cause Canadian Tax Problems

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...