US Cross-Border Tax Blog

Published by W.L. Dueck LLP

Posts filed under ‘IRS (Internal Revenue Service)’

AndersenTax

IRS Regulations Clarify 250A Deduction for Individual Owners of Non-US Corporations Subject to GILTI

Last fall, we wrote about the US’s Global Intangible Low Taxed Income (“GILTI”) and its’ adverse tax impact on US persons that own non-US corporations.   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.  Our original blog entry can be found here:   https://wldtax.com/global-intangible-low-taxed-income-gilti/ One of the concerns tax practitioners have regarding GILTI is its application to… Read More

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

Steven Flynn

Business in Vancouver – Article on how US tax reforms may impact Canadian business

Steven Flynn, a partner with W.L. Dueck & Co. LLP, was interviewed by Business in Vancouver and discussed how potential US tax reforms may impact Canadian businesses.

Steven Flynn

Changing Canadian and US Tax Law

Feedback is a valuable tool for improvement.  Whether you are a student seeking advice from a teacher, a professional listening to clients to upgrade service or a young point guard looking to beat a press (pass the basketball instead of dribbling it), we can all evaluate suggestions to help us improve.  Governments and tax authorities are no exception and often seek out comments and feedback on existing or proposed tax changes.  Recently a number of groups and organizations have offered… Read More

Steven Flynn

Changes to Certain Cross-Border Tax Amounts for 2015

As the calendar changes to 2015, both the Internal Revenue Service and Canada Revenue Agency have changed or left unchanged certain amounts and figures. Below are some of the revised amounts, numbers and limits for the year 2015 relevant to US citizens resident in Canada.