U.S. Income Tax

Global Intangible Low-Taxed Income – Simplified! The Tax Cuts and Jobs Act of 2017 (TCJA) brought some major changes for U.S. taxpayers. The Global Intangible Low-Taxed Income (GILTI) regime was enacted to tax the U.S. Shareholders of Controlled Foreign Corporations (CFC) on a current basis. TCJA introduced Transition tax and GILTI. Transition tax (Sec 965) is a one-time tax on the...

The Internal Revenue Service (IRS) has extended the deadline to file Individual income tax returns for 2020 in the U.S. The new deadline is now May 17, 2021 (the usual deadline is April 15 every year). Deadline is extended for both filing and payment of taxes, and applicable to individual taxpayers only. This includes the individuals who pay self-employment taxes as well. There is no...

A hybrid entity is an entity that has different tax treatments in different countries. The typical examples of these entities are US Limited Liability Company (LLC), Limited Liability Partnership (LLP) or Limited Liability Limited Partnerships (LLLP). We have previously published a high-level overview of the taxation of US LLCs in Canada. This post is an attempt to further explain why using...

Effective February 12, 2021, the Internal Revenue Service (IRS) has begun receiving 2020 tax returns in the U.S. In 2020, the American have moved to Canada in record numbers. Whether you have recently moved to Canada or have been living here for a while, there are a couple of things to know when it comes to your tax obligations. Disclaimer: This post is for general information purposes and...

The Internal Revenue Service (IRS) issues an Individual Taxpayer Identification Number (ITIN) for federal tax purposes. If you have the U.S. tax filing requirement and do not have a Social Security Number (SSN), you need an ITIN to file your income tax return. The IRS does not issue ITIN to whoever applies for it. There are strict rules and processes to be followed for the ITIN to be issued....

As we are in the final quarter of 2020, many wonder if they are subject to U.S. Income taxes due to the travel restrictions earlier in the year! Good News: Yes, there is an exception available! Generally, if you meet the substantial presence test (SPT), you are subject to U.S. income tax filing requirements. May Canadians spend a significant portion of the year in the U.S. especially in...

It is not unusual for Canadian businesses to expand into the United States. U.S. and Canada have two different tax systems and such a decision needs careful planning and consideration. In this post, we are going to have a quick overview of different structures that can be adopted by Canadian businesses to operate in the United States. This post is meant to be a simplified version for readers...

Canada is the second-largest trading partner of the United States. Both economies are interconnected and businesses on both sides of borders are subject to two-income tax rules of both countries. There is a Canada-US tax treaty that provides relief from double taxation. Caution: US Income tax, both for individuals and businesses, is one of the most complex tax systems in the world. The below...

U.S. Income tax is one of the most complex tax systems in the world. Being a global leader, many times international businesses get their income connected to the U.S. and they even don’t know it. The first pain-point, especially for small businesses, is an inability to determine if they are subject to U.S. tax or not! So, if you are looking for the answers to the questions like below,...

During recent times there is an uptick in E-commerce sales, especially due to COVID-19 Pandemic. With closures of more and more retail stores, customers are ordering online. Amazon is one of the biggest online retailers in the world. Many Canadian businesses have a presence on Amazon, both Amazon Canadian Store and US Stores. This post is for general purposes only and cannot be considered as...