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...
by Polaris Tax Counsel | Aug 13, 2018 | Cross-Border Tax
This article addresses complex topics in a summary fashion and does not exhaustively discuss all potential issues. It is not intended to be legal advice and cannot be relied upon as such. On August 1, the IRS released 250 pages of explanations and proposed...
by Polaris Tax Counsel | Feb 28, 2018 | Cross-Border Tax
Canadian residents who aren’t U.S. citizens may be surprised to know that U.S. estate tax can apply to them. Newly enacted U.S. tax rules have increased the exemption amount, but there are still pitfalls to be aware of. The way U.S. estate tax works has not really...
by Polaris Tax Counsel | Feb 19, 2018 | Cross-Border Tax
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...
by Polaris Tax Counsel | Feb 16, 2018 | Cross-Border Tax
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...
