Sign-up for Tax Tips and/or the Non-Arm's Length News on the right side of the page.

U.S. Tax Tips

Feb 05, 2021

What a Start for 2021!

Welcome to the New Year and our first Cadesky U.S. Tax Tip for 2021.  Everyone here at Cadesky U.S. Tax hopes that you, and your loved ones, managed to keep safe (as much as possible!). It has certainly been an interesting start for 2021!

On January 5, 2021 the State of Georgia held runoff elections for their two Senate seats.  Republican David Purdue and Democrat Raphael Warnock, led the respective popular vote held on November 5, 2020.

Aug 21, 2020

GILTI (Global Intangible Low Taxed Income)

There are a couple of developments on the GILTI front that readers may find interesting.  First, last month the IRS issued final and proposed regulations involving GILTI and the high-tax exclusion.  Second, one of Democratic U.S. Presidential nominee Joe Biden’s tax proposals is the doubling of the effective GILTI corporate tax rate from 10.5% to 21%.

To understand the potential impact of these, you first need to have a general understanding of what the GILTI provisions are meant to do and their current impact.

Jun 23, 2020

Revocable Living Trusts

It is a fairly common estate planning technique in the United States to utilize a revocable living trust (“RLT”) as part of a “United States person’s” estate planning. For U.S. estate tax purposes, a United States person would include a U.S. citizen and a U.S. domiciliary. What is not so common though, is the potential foreign impact when the underlying U.S. grantor moves to a foreign jurisdiction.

Tax Tips

Oct 09, 2020

New Trust Reporting Requirements Starting 2021

As part of the Canadian government’s efforts to combat money laundering, aggressive tax avoidance and tax evasion activities relating to trusts, enhanced income tax reporting requirements for certain trusts will be required for the 2021 and subsequent taxation years.  The new rules also contain harsh penalties for knowingly fail to comply with the new trust reporting requirements or non-compliance due to gross negligence…

Jul 29, 2020

CRA Extensions v1.1

On July 27, 2020, the Canada Revenue Agency (the “CRA”) announced a further extension to the tax payment and filing due dates for certain taxes from September 1, 2020 to September 30, 2020. The extension applies to current year individual, corporate, and trust tax returns, as well as instalment payments. Interest will not be charged on these amounts if payments are made by the extended deadline of September 30, 2020. Whether or not full payment is required in order to receive this relief is unclear.

Apr 15, 2020

The Canada Emergency Wage Subsidy – The Cavalry Is Coming

The Canada Emergency Wage Subsidy (“CEWS”) legislation has been released and is now law. In general, the CEWS will reimburse eligible employers 75 per cent of the amount of remuneration paid to eligible employees (to a maximum benefit of $847 per week).

The legislation was prepared under less than ideal circumstances so it is not surprising that there are a number of questions and observations we hope the government will address. However, we can now provide more answers than in our April 7, 2020 Tax Tip.

Transfer Pricing Newsletter

Sep 27, 2017

Eaton A.P.A. cancellations were an abuse of I.R.S. discretion

This article appears in Insights vol. 4, Issue 9.  Insights… Read more »

May 29, 2017

Amazon makes the CUT – an important taxpayer win, a reminder to consider transactional evidence

This article also appears in the May issue of Insights,… Read more »

Dec 15, 2016

Is the CRA skipping dinner in the hope of getting its deserts? Digesting the “new” Canadian transfer pricing documentation standard

The CRA was recently asked “Will the CRA’s expectations of… Read more »