Tax Treaty Benefits for Non-U.S. members of LLC
Question: Can a U.S. LLC claim exemption from Canadian corporate income tax under article VII of treaty if it has non-us members?
Question: Can a U.S. LLC claim exemption from Canadian corporate income tax under article VII of treaty if it has non-us members?
Passive Foreign Investment Companies (PFICs) In this post: What is a PFIC? Definition of PFIC Deep dive into PFIC definition Gross Income Test Asset Test Exceptions – What is not PFIC? Controlled Foreign Corporations (CFCs)
Question: I Am An IT Professional. I Just Received An Offer From My Employer. My Employer Wants Me To Incorporate And They Have Agreed To Offer A Better Hourly Rate. I Am Confused Should I Set Up A Corporation Or Become An Employee?
Question: My mother passed away in India last month. I am receiving my share of the family house. The home is located in India. I am a resident of Canada. Do I need to pay taxes in Canada when this property is transferred to me?
Question: My corporation, a CCPC, has a catering business and holds a building as an asset. I rent a portion of the building but use the rest in my operations. Is my corporation now Specified Investment Business?
Canada is going the extra mile to support the Ukrainians affected by the Russian Invasion. With every passing day number of applications for temporary residence is growing. Many of the Ukrainians are already in Canada
A lot of taxpayers emigrate from Canada every year, some to the south of the border and others beyond. In Canada, generally, the owners of the residential property are exempt from the taxes on capital
The U.S. tax system went through a major overhaul as a result of the Tax Cuts and Jobs Act (TCJA). Beginning in 2018, the U.S. taxes individuals on worldwide income whereas corporations on a Quasi-territorial
IRS form 5471, Information Return of U.S. Persons With Respect to Certain Foreign Corporations, is one of the most complex forms in the U.S. Expat tax return package. The form has evolved significantly post-TCJA to
How to calculate foreign accrual property income for a Canadian corporation.