US Cross-Border Tax Blog

Published by W.L. Dueck LLP

Posts filed under ‘Tax Implications’


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


Don’t forget about State and Local income tax implications when working in the US!

The domestic tax implications of living and working in one country are generally straight-forward.  While there may be from time to time some complicating domestic tax issues, generally, with a bit of resourcefulness you don’t need to be a tax specialist to resolve the personal tax matter (although you may like to hand it off to a professional!). When a Canadian resident individual working for a Canadian employer starts to work in the United States for that employer, the taxation… Read More