US Cross-Border Tax Blog

Published by W.L. Dueck LLP

Welcome to W.L. Dueck & Co. LLP’s US and cross-border tax blog. We are a team of over 20 tax professionals that work exclusively on US and cross-border tax issues. Our clients include Canadian businesses and individuals with investments in the US and US citizens resident in Canada. We provide both tax consulting and tax return preparation services. We work with individual and business clients and their legal, accounting and financial advisors.

Paula Owen

Moving from Canada to the US? Save Money with Canada Pension Plan

Moving to another country presents significant tax planning opportunities, especially if you are moving from Canada to the US. A commonly overlooked tax strategy for incorporated professionals and other intercompany transferees is to avoid US Social Security and Medicare by continuing their coverage under Canada Pension Plan. The tax savings can reach more than US$10,000 annually and more for up to 5 years for qualifying persons. Many taxpayers confuse Canada Pension Plan and US Social Security as investment strategies. Both… Read More

Mo Aafi

Live CPE Strafford Webinar on PFIC Reporting 2018 – Thursday, January 18, 2018

I am looking forward to speaking at the upcoming Strafford live webinar, “Form 8621 PFIC Reporting: Navigating the Complex IRS Passive Foreign Investment Company Rules” scheduled for Thursday, January 18, 2018 1:00 pm-2:50 pm EST | 10:00 am- 11:50 am PST. Our panel will present tax advisers with a thorough and practical guide to the reporting of investments in a Passive Foreign Investment Company (“PFIC”) on IRS Form 8621. The panel will identify those investments that require PFIC reporting, outline… Read More

Steven Flynn

US Tax Reform – Getting Closer to the End

Quite the week for tax professionals in Canada and the US.  On Wednesday, Finance Minister Bill Morneau provided guidance on how Canada’s income splitting rules will apply to private corporations.  You can read more about it here Detailed Comments: www.fin.gc.ca/n17/17-124-eng.asp Guidance : https://www.canada.ca/en/revenue-agency/programs/about-canada-revenue-agency-cra/federal-government-budgets/income-sprinkling.html   On Friday, the House and Senate reached a compromise on their different US tax bills.  Details were released Friday and many anticipate the single document being signed into law next week.  Mary Duffy at Andersen Tax… Read More

Catherine Shen-Weafer

Is the interest expense deductible for US non-resident aliens owning a US real property interest?

Loaning between business entities is a widely-adopted business strategy in the real estate industry. Multiple levels of entities are often chosen in a business structure. U.S. limited liability companies (“LLC”) are commonly used to hold U.S. real property interests. When foreign investors are involved for various reasons (i.e., asset protection), foreign investors use a non-U.S. corporation that is treated as a disregarded entity for U.S. federal income tax purposes to be the sole owner of the U.S. LLC. When the… Read More

WLDTax

Outbound Issues – Ownership of Non-US Corporations Subpart F Income

3 Day Tax Conference November 15 – 17, 2017 – Burbank, CA Join Steven Flynn, a partner with W.L. Dueck & Co. LLP at an upcoming CalCPA Tax Conference in Burbank, Los Angeles on November 15 – 17.  During this Federal, State, Local & International Taxation Conference, Steven will bring expertise on Outbound Issues, Ownership of Non-US Corporations Subpart F Income, including: What is a Controlled Foreign Corporation? When do the Subpart F rules apply? Why is it a problem?… Read More