Authors: Kul Makkar, Tan Garg (International Tax Advisors Canada) How would you determine that the price at which you are selling goods or services to your US subsidiary or branch is acceptable to both Canadian and US tax authorities? Essentially, any transaction between a related Canadian and overseas enterprise must successfully pass the test of arm’s … Continue reading Transfer Pricing – Concept and Procedures
Expatriation tax is imposed on individuals who renounce their U.S. citizenship and certain long-term U.S. residents who terminate their residency status. This tax regime was introduced in 1966 and has been subsequently amended many times. The most current version of this tax regime is outlined in the Heroes Earnings Assistance and Relief Act (HEART) of … Continue reading US Expatriation Tax
If you are a Canadian citizen who has properties you want to give away in the United States, and if you know anyone who is deceased and thinking of transferring property, you may want to know about the tax implications surrounding how U.S. gift tax and estate tax affects Canadians. U.S. gift tax system creates … Continue reading U.S. Gift and Estate Taxes for Canadians
Are you a Canadian resident who travels to the United States frequently? If so, it is important that you are aware of the “Substantial Presence Test”. This assessment is issued by the IRS and is used to establish the tax status of a non-resident. Calculations are based upon the number of days an individual intends … Continue reading U.S. Tax Implications for Canadians Who Temporarily Work or Live in the U.S.
One of the most significant road blocks for Canadian real estate investors looking to invest in Canada or the United States is the significant tax implications that may arise. That is why it is crucial that you utilize the best type of partnership structure for your situation. In this presentation, Allan Madan explains the tax … Continue reading Tax Tips for Canadians Investing in American Real Estate
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