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...
by Polaris Tax Counsel | May 15, 2019 | Cross-Border Tax
Many Canadian tax-exempt organizations invest in the United States as part of a diversified portfolio. As these investors are exempt from tax in Canada, any US tax paid on the investments is a net cost to them. Thus, eliminating US tax is an important step to...
by Polaris Tax Counsel | Mar 4, 2019 | Cross-Border Tax
In recently released proposed regulations related (see pages 49-50, 53, 70-71) to the impact of GILTI on individual US taxpayers, the IRS has surprisingly taken a taxpayer friendly position. They are allowing the 50% deduction against GILTI income if an individual...
