US Cross-Border Tax Blog

Published by W.L. Dueck LLP

Posts filed under ‘NRA (Non-Resident Alien)’

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

AndersenTax

Canada US Tax Treaty – US Nonresident Alien Using “Married Filing Joint” Tax Rates

Two recent client situations remind us that certain provisions in the Canada US Income Tax Convention (“Treaty”) can lower a client’s overall tax liability even where the answer isn’t so obvious when entering information in tax software.   The first example is the subject of today’s blog.  The second example will be posted later this month. A Canadian resident, nonresident alien of the US worked in the US in 2012 as an employee.  The individual was married and his spouse did… Read More

AndersenTax

Extending the US Tax Filing Deadline

Mention the date April 15th to a US person and their first thought probably turns to taxes.  Individuals who are required to file a US income tax return are generally required to file their return on or before April 15th provided that the date falls on a weekday.  In years when the 15th falls on a weekend, the due date is delayed to the first business day after the weekend.  It gets a little more complicated to determine the correct… 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