by Polaris Tax Counsel | Jan 13, 2018 | Cross-Border Tax
This blog post addresses a very technical question about the new US repatriation tax. It will only be of interest to US tax advisors. It is not meant as legal advice and cannot be relied upon as such. It involves complex US tax concepts so advice specific to the...
by Polaris Tax Counsel | Dec 3, 2017 | Cross-Border Tax
The United States is in the throes of the most comprehensive tax reform since 1986. On November 16, the House passed its version of the Tax Cuts and Jobs Act (“TCJA”). The Senate passed its version on December 2. While there are significant differences,...
by Polaris Tax Counsel | Nov 14, 2017 | Cross-Border Tax
On November 2, 2017, the US House of Representatives unveiled the Tax Cuts and Jobs Act which contains the most sweeping changes to US tax law in 30 years. While it remains unclear whether, when, or in what form the new bill will become law, but if it passes in its...
by Polaris Tax Counsel | Nov 2, 2017 | Cross-Border Tax
On November 2, 2017, the House of Representatives unveiled the most sweeping reforms to US tax law in 30 years. If passed, it will make matters worse for some US citizens in Canada and keep it the same for others. Some key implications include: No elimination of...
by Polaris Tax Counsel | Mar 31, 2017 | Cross-Border Tax
Many Canadian start-ups, whether junior mining, biotech, or tech, receive funding from investors in the United States (or from US taxpayers who reside in Canada). If the proper steps are not taken, a punitive US tax regime (the passive foreign investment company or...
by Polaris Tax Counsel | Mar 10, 2017 | Cross-Border Tax
Last May, the U.S. Department of Justice sued Jeffrey P. Pomerantz — a Canadian resident, US citizen — for over USD $860,300 in penalties and interest for failing to file his FBAR bank disclosure forms. This case is one of the first known instances of the...