by Polaris Tax Counsel | Mar 3, 2020 | Cross-Border Tax
New IRS guidance exempt RESPs and RDSPs, but not TFSAs from annual US information reporting requirements. Our view remains that TFSAs are not foreign trusts and thus not subject to 3520 + 3520-A reporting (read more). All told, with this Revenue Procedure US taxpayers...
by Polaris Tax Counsel | Oct 30, 2019 | Cross-Border Tax
Many Canadian tax-exempt investors invest in US equities through a standard Canadian pooled fund. This means that they pay the 15% US dividend withholding tax on US equity investments. This can be refunded. To illustrate, assume that a Canadian charity invests in...
by Polaris Tax Counsel | Oct 2, 2019 | Cross-Border Tax
In tax year 2018, the coverage of Form 8858 was expanded to require the reporting of not only interests related to foreign disregarded entities (“FDEs”), but also foreign branches (“FBs”). This revision to Form 8858 to expand its coverage to FBs have given rise to...
by Polaris Tax Counsel | Jun 17, 2019 | Cross-Border Tax
A common and problematic occurrence in cross-border families is for a Canadian to select a close relative in the U.S. as an executor. Clients considering this option should weigh the potential consequences. To illustrate the problems, let’s use an example. Fictional...
by Polaris Tax Counsel | Jun 10, 2019 | Cross-Border Tax
Canadians who own US real estate need to make sure that their wishes after they die are carried out on both sides of the border. This is a different issue than the US federal estate tax exposure faced by Canadians who own US assets. Each Canadian province and US state...
by Polaris Tax Counsel | Jun 10, 2019 | Cross-Border Tax
Recently, the IRS has significantly increased in the number of penalties issued for late or incorrectly filed Form 3250 (“Annual Return To Report Transactions With Foreign Trusts and Receipt of Certain Foreign Gifts”) and Form 3520-A (“Annual Information Return of...
