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Income tax in Canada is duly administered by Canada Revenue-Agency. The time period taken into account is between January 1 and December 31 of a financial year. In case you owe personal...
Posted by The Accounting and Tax on 08/20/2019
As per research and entrepreneurial statistics, Canada is the perfect place to start a business. The low cost of living as well as the enormous government support that the natives...
Posted by The Accounting and Tax on 08/09/2019
The beauty of Canada is unbelievable. Here you can find wonderful landscapes such as mountains, glaciers, lakes, forests, etc. You will surely be delighted by its striking sceneries....
Posted by The Accounting and Tax on 08/09/2019
As per research and entrepreneurial statistics, Canada is the perfect place to start a business. The low cost of living as well as the enormous government support that the natives...
Posted by The Accounting and Tax on 07/18/2019
Even though tax comprises a lot of things that come as benefits such as healthcare or education, there is a common belief that Canadians pay more taxes than their American counterparts....
Posted by The Accounting and Tax on 06/22/2019
While migrating to a different country, one of the very first thoughts that come to your mind is the infrastructure and provisions for healthcare in the place that you might call your...
Posted by The Accounting and Tax on 06/22/2019
Tax consultants in Toronto and other Canadian cities follow a dual rate system for corporate income tax. If a business’ corporate income falls below a certain level, it pays...
Posted by The Accounting and Tax on 05/27/2019
If you are a Canadian and own a small business in your home, then you may wish to pay a lower amount of tax and may look for opportunities to claim tax write-offs. You can easily assume...
Posted by The Accounting and Tax on 05/27/2019
Feeling helpless while trying to manage your taxes is not something to be bothered with. You’re not the only one who goes through these problems, and there are several tax consultants...
Posted by The Accounting and Tax on 05/27/2019
You can be a freelancer, a self-employed worker or even a small business owner; but, when you’re in Canada, the Canadian Revenue Agency (CRA) will always handle your income tax...
Posted by The Accounting and Tax on 05/26/2019
14.3.1 [a] U.S Taxation of Canadian Residents on Personal Services IncomeUnder the Code, non-resident aliens who earn income in the U.S. are subject to federal income tax on the portion...
Posted by The Accounting and Tax on 01/21/2019
14.2.2[a] Independent Personal ServicesArticle XIV governs income earned by an individual from independent personal services. Any type of business or professional activity could qualify...
Posted by The Accounting and Tax on 01/21/2019
14.1 Introduction to Article XIV – Independent Personal ServicesArticle XIV deals with the provision of independent services in one Contracting State by an individual who is...
Posted by The Accounting and Tax on 12/06/2018
13.3.2 [a] Article XIII(1) – Gains from Real PropertyParagraph 1 authorizes the U.S. to tax gains derived by a resident of Canada from the alienation of real property situated...
Posted by The Accounting and Tax on 11/26/2018
13.3.1 [a] Taxation of Gains by Non-resident Aliens and Foreign CorporationsThe United States generally imposes a flat 30 percent tax, collected by withholding, on the gross amount...
Posted by The Accounting and Tax on 11/22/2018
In an arm’s length transaction persons will act in their separate interest. It is a transaction that reflects ordinary commercial dealings between parties acting in their separate...
Posted by The Accounting and Tax on 11/08/2018
13.2.2 [a] Article XIII(1) – Gains from Real PropertyArticle XIII(1) provides that the gains derived by a U.S. resident from the alienation of real property situated in Canada...
Posted by The Accounting and Tax on 10/30/2018
If you are not a U.S citizen or a green card holder and you are departing from the U.S. you are required to obtain a certificate of compliance from the IRS.You must contact your local...
Posted by The Accounting and Tax on 10/30/2018
13.2.1 Canadian Taxation of Gains of Non-ResidentsCanada does not impose tax on gains from the disposition of property by a non-resident other than the disposition of taxable Canadian...
Posted by The Accounting and Tax on 10/22/2018
You need to appraise your situation before deciding to go for a bankruptcy.Take a look at your budget and debt worksheet and look for answers to following questions.1 – Is there...
Posted by The Accounting and Tax on 10/06/2018
Canadian Border Services Agency (CBSA) and US Customs and Broker Protection (CBP) have implemented many new rules that have affected Canadians who wish to live the cross-border lifestyle.In...
Posted by The Accounting and Tax on 10/06/2018
Article XIII generally deals with the taxation of capital gains realized by residents of Canada or the U.S. that may be also taxed in the other State. The general rule dealing...
Posted by The Accounting and Tax on 10/06/2018
12.3.2[a] Article XII(1) – Residence – Based Jurisdiction to TaxParagraph 1 of Article XII stands for the proposition that a resident of a country receiving royalty income...
Posted by The Accounting and Tax on 10/06/2018
Wills are a primary tool in Canada to govern your estate affairs.In U.S. living trusts are common because they are “flow through” entities taxed at your personal rates....
Posted by The Accounting and Tax on 08/14/2018
12.3.1 U.S. Taxation of Outbound Royalty Payments 12.3.1[a] Definition of RoyaltiesThe Code generally defines the term “royalty” by enumerating the kinds of property...
Posted by The Accounting and Tax on 08/14/2018
If you are U.S green cardholder or citizen and wish to move to Canada, you need to do some planning before you make the move to Canada.Tax planning is absolutely different than tax...
Posted by The Accounting and Tax on 06/25/2018
The Timeline for US Expats to File Income TaxJust as any other citizen of USA, expats living and working in a foreign country are subjected to income tax laws. While there are some...
Posted by The Accounting and Tax on 06/25/2018
11.3 Explanation & Interpretation of Article XI under U.S. Law 11.3.1 U.S Domestic Taxation of Interest Paid to Canadian Residents11.3.1[a] Definition of InterestInterest...
Posted by The Accounting and Tax on 06/25/2018
11.3.2[a] Article XI(1) – Residence – based Jurisdiction to TaxParagraph 1 of the Article preserves the right of a Contracting State to tax income earned by its residents,...
Posted by The Accounting and Tax on 06/25/2018
Of the many reasons why so many people want to migrate to Canada is the privileges that they can avail when in Canada. However while living in Canada and once you start earning here...
Posted by The Accounting and Tax on 03/19/2018
You may be in your early 20s and might have just started earning. It is possible that you have big financial dreams of building a huge financial wealth at some point of time. What...
Posted by The Accounting and Tax on 03/19/2018
In case you are an immigrant to Canada you would know that, Canada is a cultural mosaic, with people from all over the world now calling it their home. So as an immigrant here apart...
Posted by The Accounting and Tax on 03/19/2018
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
CreditCards have many benefits provided you know how to use them rightly.You need to be disciplined about how you use them and also about there payments on their balances. Let us discuss...
Posted by The Accounting and Tax on 02/28/2018
You would already know that purchasing real estate as an investment could be more secure. The reason is quite simple. It is seen that the super-rich class often buy the luxury real...
Posted by The Accounting and Tax on 02/13/2018
When it comes to our habits every individual has certain good habits and some bad habits. It is no different with financial habits as well. As individuals we need to make our good...
Posted by The Accounting and Tax on 01/02/2018
Whether we are working at a job or building our own business, we always want our money to grow. One great way to do so is investing the money we earn. But it is important to understand...
Posted by The Accounting and Tax on 12/16/2017
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
At present we are in the midst of uncertain financial times. Owing to the uncertainties it was seen that the average Canadian debt balances rose by 2.3% in the 2016 3rd quarter, which...
Posted by The Accounting and Tax on 12/01/2017
Whether it be Replacement of your vehicle with a used car or buying a new car, it is always a big decision. It might be the second biggest one, following the decision to buy a house....
Posted by The Accounting and Tax on 12/01/2017
You might have thought to have a well-settled life financially. However, these would not happen automatically and you must realize that you need to act to make the same happen. We...
Posted by The Accounting and Tax on 10/23/2017
Are you considering renting a place? If so you must be wondering about the amount of rent you can afford. There are of course many ways to approach the same. The following are some...
Posted by The Accounting and Tax on 10/14/2017
7.3.2 [a] Taxation of the Business Profits of a Canadian ResidentParagraph 1 of the Article VII of the Treaty provides that the business profits of a Canadian resident will only be...
Posted by The Accounting and Tax on 09/09/2017
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
Spending money can be fun. But you also need to realize that your spending habits are very important and in some ways determine your financial success. It is just as important as saving...
Posted by The Accounting and Tax on 09/07/2017
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
7 . 2 . 1 (a)In general, the net business profits of a non-resident carrying on business or any other income generating activities in Canada are subject to the income tax imposed under...
Posted by The Accounting and Tax on 08/31/2017
Generally, Article VII provides that the business profits of a person resident in one Contracting State should not be taxable in the other Contracting State unless the particular...
Posted by The Accounting and Tax on 08/31/2017
IntroductionThis article of the treaty talks about following points:1 – The business profits of a resident of a Contracting State shall be taxable only in the State unless the...
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...
5.2.1[a] Taxation of Income of Non-Residents GenerallyA non-resident person is subject to Part I tax in Canada if the non-resident, at any time in a taxation year,1 – Was employed...
Posted by The Accounting and Tax on 06/21/2016
5.2.2[a] Article V(1) – Definition of Permanent EstablishmentArticle V (1) provides a general concept of the notion of “permanent establishment” for the purposes of the Treaty.For...
Article IV(3)A situation of dual Resident Corporation may arise if a corporation is considered a resident in the U.S. under the treaty by virtue of its incorporation in the U.S.,...
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...
4.5.2 [a] New Tie-Breaker RuleIf a particular company is a resident of both Canada and the United States, the language of new Article IV(3)[a] provides that where a company...
4.3.2 (a) Article IV(1) ResidencyForeign persons generating income from U.S. sources are potentially subject to one, or both, of two U.S federal taxation regimes dealing...
Dual Resident Individuals...
Posted by The Accounting and Tax on 04/11/2016
Treaty Concept of Residency (Canadian Interpretation of the Treaty)...
Posted by The Accounting and Tax on 04/07/2016
Canada U.S Tax Treaty Article 4 - Residency...
Posted by The Accounting and Tax on 04/01/2016
Foreign Persons doing Business in the United States...
Posted by The Accounting and Tax on 03/27/2016
Tax issues of foreign persons in the United States...
Posted by The Accounting and Tax on 02/16/2016
Planning for outbound transactions...
Posted by The Accounting and Tax on 02/11/2016
Tax Issues...
Posted by The Accounting and Tax on 02/05/2016
Sale of Export Property...
Rules for determination of amount, timing, character and source of foreign currency gains and loss are present in code section 988. Following transactions are included in code section...
Posted by The Accounting and Tax on 01/28/2016
Currency translation issues:Foreign branches and subsidiaries keep their books and records in the currency of host country.Parent companies in USA are required to compute their taxable...
Posted by The Accounting and Tax on 01/27/2016
Background:U.S investors in foreign mutual funds could avoid U.S taxes. The fund itself could avoid U.S taxes because it was a foreign corporation that only derived foreign source...
USA will only tax foreign business earnings if it repatriates it to USA through dividends. This policy is known as “deferral”. Deferral creates an opportunity for avoiding...
Posted by The Accounting and Tax on 01/10/2016
A general rule for tax planning for dividend repatriation includes cross-crediting, minimizing foreign withholding taxes and considering alternative methods of repatriating earnings. Cross-Crediting If...
Posted by The Accounting and Tax on 01/06/2016
Who can claim a deemed paid tax credit? - A domestic “C” corporation that owns 10% or more of the voting stock and receives...
Posted by The Accounting and Tax on 01/02/2016
Who can claim a deemed paid tax credit? - A domestic “C” corporation that owns 10% or more of the voting stock and receives...
Posted by The Accounting and Tax on 12/28/2015
If foreign tax credits exceed the limitation in a given taxable year, these can be carried back one year and forward up to ten years. Excess credits on general limitation income...
Posted by The Accounting and Tax on 12/25/2015
Capital gains and losses receive a special treatment under U.S tax law. Individual capital gains and losses are netted. Non corporate taxpayer’s net capital gains get a preferred...
Posted by The Accounting and Tax on 12/23/2015
General Income: It includes all income other than passive income. It includes most of the foreign source active business profits of domestic corporations and their foreign subsidiaries. Passive...
After computation of creditable foreign income taxes, next step is to compute foreign tax credit limitation. Example: USAco has U.S source income = 200 Foreign source taxable...
The United States restricts the credit to foreign income taxes that duplicate the U.S income tax against which the credit is taken. Under code section 901, a foreign levy must...
Bases for asserting jurisdictions Who to tax? What income to tax? Personal relationship between a taxpayer and the country This concept also applies to corporations and other type...
Cash Flow – Making Projections Cash from line items consists of depreciation schedule, working capital schedule or debt schedule. We must complete depreciation and working capital...
Making projections from income statement requires: ü Spending a lot of time. ü Research and understand core of business model. ü Understand Revenue...
Canadian citizens working in the United States are usually not sure if they should be filing taxes in Canada. According to CRA if someone is not considered to be a resident of Canada...
All businesses are required to report sales and income over a taxation year. Profits = Sales – Expenses Net Income = Profits – Taxes Categories included in an income...
Posted by The Accounting and Tax on 05/07/2015
Living a good life can be owning a home, owing a business, being debt free, driving a high end car or having a good investment portfolio. These goals are achievable with a strong financial...
Gross income comes from following categories of income: Interest, Dividends, Personal Services, Rentals, Royalties, Gains from disposition of property. Leasing generates rental income....
Posted by The Accounting and Tax on 03/05/2015
Saving tax dollars is an art. Filing taxes in time can save you from penalties. Making timely tax installments can also save you from penalties. In Canada, personal tax return is...
Source of income can have significant impact on calculation of foreign tax credit limitation. Formula for foreign tax credit limitation = Pre-credit U.S tax x foreign...
Income of a Taxpayer Salary, wages, remunerations, for services and gratuities received by a taxpayer are all considered as income of a taxpayer. These types of incomes are taxable...
Financial planning should not be difficult. It is basically a plan to save for your retirement, education of your children or buying a house. You should clarify your goals and set...
Code Section 7701 (b)(2)(A)(iii) U.S residency start date depends on two things: ü Residency is established under the green card test. ü Residency is established...
U.S Internal Revenue code does not give any special status to RRSP, TFSA, RESP, RPP or DSPS plans. If an employer contributes to a registered pension plan or a deferred profit-sharing...
Resident aliens in the United States are taxed on their world wide income. Nonresident aliens are taxed on their U.S source income. Code Section 7701(b)(1)(A) An alien will be considered...
Posted by The Accounting and Tax on 01/05/2015
The following items are not included in income of taxpayer for a taxation year: Amounts declared to be exempt by legislation of the Parliament of Canada (s. 81(1)(a)) Amounts received...
U.S Tax law requires substantial amount of financial information. If you or your family members control directly or indirectly any non-US corporation and you have holdings in it, you...
Code Section 7701 (a)(30) U.S citizens are U.S Persons and Citizens of foreign countries are U.S Persons who meet either of the following two tests: Green Card test Substantial...
The following items are included in income of taxpayer for a taxation year: Alimony or maintenance payments (s. 56(1)(b) and s. 56(1)(e)) Allowances for personal, living, or any...
A corporation is liable to pay tax if: - It is a resident corporation of Canada - ...
The United States taxes its citizens on their world income even if they are not present in the United states. Canada taxes its residents on their would income. U.S Citizens...
If a taxpayer has personal relations with one country (Home) and derives income from another country (Host) it can cause a double taxation issue. The host country will most likely...
Multinational Companies do lot of intercompany transactions. U.S manufacturers market their products in foreign countries through their subsidiaries. Domestic parent companies sometimes...
Ref Code Section 871 (b) and 882: According to these code sections if a foreign person is engaged in a U.S trade or business, he is subject to U.S taxes for any income that is connected...
Posted by The Accounting and Tax on 12/10/2014
Foreign Corporations and non-resident aliens who have a U.S source income are subject to U.S Taxation. According to codes section 871 (b) and 882, all Foreign Persons are taxed at...
If a domestic corporation has a foreign subsidiary, this subsidiary will usually maintain its books and records in the currency of the country where it exists. If this subsidiary repatriates...
Deemed Paid Foreign Tax Credit U.S.A If a domestic Corporation receives dividends from foreign Corporation it usually cannot claim a deduction for dividends received. These dividends...
Code Section 901: According to this code section if a U.S Citizen, a resident alien or a domestic corporation pays foreign income taxes it can claim credit for it when filing...
Refer Code section 904: Limitation on Credit: Source of income rules play a very vital role when it comes to computation of foreign tax credits limitation of a taxpayer. If foreign...
For international transactions Governments have to decide which person and what income needs to be taxed. The basis for this can be personal relationship and economic relationship. Personal...
Posted by The Accounting and Tax on 10/28/2014