10.3.2[a] Article X[1] Residence based Jurisdiction to Tax Paragraph1 of the Article X recognizes the right of a Contracting State to taxdividend income received by a resident...
Posted by The Accounting and Tax on 03/13/2018
A Limited Liability Company (LLC) is not recognized by the IRS and is not a separate entity. The IRS calls it a “pass-through entity” because its profits and losses are...
Posted by US and International Business Services on 03/08/2018
9.3.2 [a] Arm’s Length StandardArticle 9 incorporates into the Treaty the arm’s length principles reflected and noted above in U.S. domestic law. In its most basic dimensions,...
Posted by The Accounting and Tax on 12/05/2017
7.3.1 [a] U.S. Taxation of Income of Foreign PersonsForeign persons generating income from U.S. sources are potentially subject to one, or both, of two U.S. federal taxation regimes....
Posted by The Accounting and Tax on 09/09/2017
7.2.2 [a] Article Vii[1]Business Profits – Taxation of Profits Attributable to a permanent EstablishmentBusiness profits of a U.S. resident carrying on a business in Canada are...
Posted by The Accounting and Tax on 08/31/2017
6.3.1 Taxation of Investments in U.S Real Property by Canadian Investors6.3.1 (a) - IntroductionThere are many tax and legal considerations that must be weighed before making an investment...
Posted by The Accounting and Tax on 07/28/2016
6.1 IntroductionArticle VI (Income from Real Property) affirms the jurisdictional powers of the source State to impose its income tax on income derived by the resident of the residence...
5.3.1[a] U.S. Taxation of Foreign PersonsThe U.S. tax treatment of foreign persons and foreign-related transactions depends primarily on three criteria:1 – Whether the income earned...
4.3.1 (a) Residence of IndividualsUnder U.S domestic tax law, all individuals are subject to U.S tax, unless specifically exempted.U.S citizens are subject to U.S. tax on a worldwide...