Wayfair, you’re just what I don’t need South Dakota v. Wayfair, Inc. et al Major Changes Coming for U.S. Sales Tax
As Canadian companies grow their business into the United States one area of planning that is often…
Investing with a Foreign Broker and Buying Canadian Shares
Foreign brokers can attract Canadian investors, perhaps because of low management fees. The foreign broker may purchase…
Volume 1 No. 1
Major Tax Overhaul Adopted In U.S. And Its Effect On Cross Border Investors by Stanley C. Ruchelman…
What is my U.S. taxable year (as it relates to certain Canadian corporations)?
The recently enacted U.S. Tax Cuts and Jobs Act introduced new IRC §965, “Treatment of Deferred Foreign…
IRS Provides Some Relief For U.S. Taxpayers Abroad in Meeting the Repatriation Tax Payment Deadlines
Yesterday, April 2, 2018, the IRS released Notice 2018-26, the long-awaited additional guidance related to the one-time…
Understanding U.S. Due Dates, Extensions and Payment Dates
The due date for a U.S. personal income tax return will depend on both the residence of…
Understanding the U.S. Days Counting Test and U.S. Tax Residency
In most countries an individual’s tax residency is determined by their residential ties, which considers one’s own…
IRS Announces the end of the Offshore Voluntary Disclosure Program though Streamlined is still around – for now
On March 13, 2018 the Internal Revenue Service announced (IR-2018-52) that it will close the 2014 Offshore…
The importance of E&P – Will you be paying the right amount of tax to the IRS?
An accurate determination of “earnings and profits” (E&P) of a foreign (i.e., Canadian) corporation is often an…
IRS Form 5472 : An easy but expensive filing obligation to overlook?
Recent media coverage, as it relates to U.S. tax in Canada, has almost entirely focused on the…
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