On September 28, 2018, i.e. in four days, the IRS is terminating the 2014 Offshore Voluntary Disclosure Program (O.V.D.P.) which may trigger very serious legal consequences for eligible non-compliant US taxpayers. The program allows US persons who are willfully non-compliant with their US tax- and foreign financial accounts reporting obligations to avoid criminal charges and excessive civil penalties that would otherwise apply, by voluntarily disclosing all […]
Effective for tax years after December 31, 2017, as part of the Tax Cuts and Jobs Act, certain significant changes were made to profits recognition from sales derived from production activities in Canada and furnished to the US (and vice-versa). Previously, the sales were generally sourced based on a 50/50 method. For Canadian businesses that manufactured […]
Virtual currency and the repatriation of foreign profits under Section 965 are the two out of five most recently added IRS compliance campaigns administered by the IRS Large Business and International (“LB&I”) Division. The objective of the narrowly defined campaigns is to “improve return selection, identify issues representing a risk of non-compliance, and make the […]
The first installment payment due date for the Transition Tax is fast approaching, due June 15, 2018 for US individual shareholders whose tax homes and abodes are outside of the United States and Puerto Rico. On June 4, 2018, the IRS released additional guidance and relief in respect of the transition tax, which may be […]
If you are an individual US shareholder of a controlled foreign corporation (CFC), residing in the US, who paid or is expected to pay the transition tax in 2017, you may be able to recover some or all of the transition tax paid. This can be done by paying yourself a dividend from the CFC […]
If you are in the business of accounting, tax and/or law, you are likely experiencing an influx of clients who need help with IRC Section 965, Mandatory Repatriation Tax. The rules are very complex, the results can be quite punitive, and the direction we have received from the IRS to-date has been vague, at best. […]
On March 13, 2018, the IRS announced that it will be winding down its 2014 Offshore Voluntary Disclosure Program (“OVDP”) by September 28, 2018. The OVDP is a modified version of earlier OVDP’s and was made available to taxpayers who wish to voluntarily disclose their offshore accounts and assets to avoid the risk of criminal […]
First and foremost, a Canadian should not create an LLC to acquire FL real estate, or any US real estate for that matter. This is the biggest mistake Canadians make as they fall prey to local advisors who have promoted the LLCs as the best vehicle to do business in the US or own real […]
Canada’s latest budget proposes increasing tax authority resources, toughening beneficial ownership reporting requirements for trusts, and further amending rules to limit the advantages of holding passive savings in a corporation. In its 2018 budget plan, announced February 27, the Canadian Department of Finance focused on measures to ensure a “fair tax system for all Canadians,” […]
Q: I am a US resident and I just inherited a Registered Retirement Savings Plan (“RRSP”) from a Canadian resident. Do I have to pay tax in Canada or in the US on the RRSP distribution? A: Yes and no. As a named beneficiary of the inherited RRSP account, who is not the spouse of […]