Entries by Elena Hanson CPA
US Persons with Foreign Interests may be overlooking important reporting requirements
U.S. citizens or residents who are officers or directors of a foreign corporation (e.g. a Canadian corporation) often overlook their U.S. filing obligations, and it is important to understand the stiff penalties for not properly disclosing foreign interests. If a U.S. citizen or resident is an officer or a director of a foreign corporation in […]
The Anti-Abuse Rules under Transition Tax (Section 965) Final Regulations
Code Section 965 of the Tax Cuts and Jobs Act requires some US shareholders to pay a one-time transition tax on the untaxed foreign earnings of certain specified foreign corporation (“SFC”) as if those earnings had been repatriated to the US. Very generally, section 965 of the Code allows taxpayers to reduce the amount of […]
IRS shutdown may lead to complications for Canadians
With the United States government shutdown in its fifth week — the longest government shutdown in U.S. history — its effects are beginning to take a toll on those north of the border. For Canadians with financial interests in the U.S., the shutdown of non-essential government agencies such as the Internal Revenue Service may prove […]
1.6 million Canadian banking records shared with IRS
The Canadian government has shared more than 1.6 million Canadian banking records with the U.S. Internal Revenue Service since the start of a controversial information-sharing agreement in 2014, CBC News has learned. In 2016 and again in 2017, the Canada Revenue Agency provided the IRS with information on 600,000 Canadian bank accounts each year. That’s […]
Can I extend filing of my US 1040 return beyond October 15? And how about form 3520?
US citizens living outside the US (i.e. abroad) have an automatic 2-month extension of time to file the individual income tax return from April 15th to June 15th. If a further extension is needed, Form 4868 must be filed on or before June 15th, to receive an automatic extension of time to file their US […]
Can we eliminate GILTI tax by making the 962 Election?
Pursuant to Barry v Commissioner, the courts concluded that dividends paid out of a CFC (following a 962 election) in a country in which has no treaty with a US, is a dividend but taxed at ordinary rates. It has always been my understanding that if a CFC that is otherwise not a PFIC and […]