US Cross-Border Tax Blog

Published by W.L. Dueck LLP

Posts filed under ‘Federal, State And Corporate Returns (US)’

AndersenTax

Global Intangible Low-Taxed Income (“GILTI”)

The December 2017 US tax reform included a provision to subject to US tax the earnings of intellectual property owned by US investors outside the US. Known by the unfortunate name of GILTI, its application is much broader than just Apple, Amazon, Google and the like. GILTI impacts US persons resident in Canada who own Canadian and other non-US corporations. Without effective tax planning, combined US and Canadian tax rates approaching 85% could occur as early as 2018.  GILTI applies… Read More

AndersenTax

US State and Local Tax Consideration for Canadian Businesses

Often Canadian businesses are surprised to learn about the reach of US state taxing jurisdictions to assert tax on out-of-state taxpayers.  Since none of the 50 states were signatories to the Canada-US Income Tax Convention (the “Treaty”), they are not limited by the Treaty to taxing business activities in the US.  It is not uncommon to find a Canadian business subject to a state’s taxing jurisdiction and completely exempt from US federal income taxation because of the Treaty. In contrast… Read More

AndersenTax

US Filing Obligations of Non-residents of the US

There has been a lot of attention in the media about US citizens who live in Canada and their US tax filing obligations. Non-US citizens who are not resident in the US (“NRA” for non-resident aliens) may also have US tax filing obligations where they work in the US, sell US real estate or even travel to the US. Work in the US In general terms, NRAs who earn employment income while working in the US are subject to US… Read More