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, 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.
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
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.
On June 18th, the IRS released revisions to the Streamlined Procedures. Our June 19th blog entry summarized these changes and raised concerns over the non-residency requirement. In particular, the requirement that a person spend more than 330 days outside the US in each of the last three years may disqualify snowbirds, business travelers and frequent cross-border shoppers. On June 20th, the IRS sent two officials to New York University’s Tax Controversy Forum to answer audience questions. Scott Michel from Caplan… Read More