The Accounting and Tax

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Scarborough Canada

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  • The Accounting and Tax
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  • The Accounting and Tax Company Logo by The Accounting and Tax in Scarborough ON
  • Year Established:
  • 2001
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  • Phone Number
  • 416-283-8774
  • Location
  • 200 - 100 Consilium Place
    Scarborough, ON M1H 3E3
    Canada

Professional Background

More About The Accounting and Tax

I am enrolled to practice before the Internal Revenue Service under 31 Code of Federal Regulations Part 10 (Treasury Department Circular No. 230)

I specialize in expatriate taxation for U.S citizens abroad.

I also specialize in taxation of Capital Gains, Interest Income, Real Estate Rental Income and Gambling Winnings. 

Solution provider for Corporate, Soleproprietorship, Partnerships, Limited Liability Companies, S and C Corporations.

Education:

Masters of Science in Taxation.





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Article 14.1-14.2

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...


13.3.2 U.S. Interpretation of the Treaty

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...


13.3 U.S Interpretation of the Treaty

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...


What is an arm’s Length Transaction?

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

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13.2.0 Canadian Interpretation of the Treaty

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...


Departing from the U.S.

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...


13.2 Explanation & Interpretation of Article XIII Under Canadian Law

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...


Is Bankruptcy for You?

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

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How long can Canadians Remain in the U.S?

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

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13.1 Introduction to Article XIII - Gains

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

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Article 12.3.2 U.S. Interpretation of the Treaty

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

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Estate Planning in Canada

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....


Article 12.3 Explanation & Interpretation of Article XII Under U.S. Law

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...


U.S.A tax filing if you move to Canada

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...


The Timeline for US Expats to File Income Tax

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...


11.3 Explanation & Interpretation of Article XI under U.S. Law

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...


11.3.2 U.S. Interpretation of the Treaty

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,...


What as a new Canadian you must know about your First Tax Year?

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...


Investing:Best way to build wealth over time

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...


Important tax matters to know as a Canadian Immigrant

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...


10.3.2 U.S. Interpretation of the Treaty

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...


Important points regarding your Credit Card

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...


4 Important tips for investing in Luxury Real Estate

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...


5 Important Personal Finance Habits you must develop

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...


Some basic tips about investing

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...


Article 9.3.2: U.S Interpretation of the Treaty

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,...


Important Financial tips to shape up your finances

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...


5 tips to help you for a New or Used Car

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....


5 Smart things about your finances you could do

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...


How Much Rent Can you afford? A Canadian perspective

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...


Article 7.3.2: U.S. Interpretation of the Treaty

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...


U.S Taxation of Foreign Persons Doing Business in the U.S.

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....


6 quick ways to create better spending habits

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...


Article VII.2.2: Canadian Interpretation of the Treaty

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...


Article VII.2.1: Explanation & Interpretation of Article VII Under Canadian Law

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...


Article VII.1 - Business Profits

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...


Article VII – Business Profits

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...



Article VI – Income from Real Property (Canada U.S. Tax Treaty)

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 Explanation & Interpretation of Article V under U.S. Law (Canada U.S. Tax Treaty)

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 Explanation & Interpretation of Article V under Canadian Law

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...


5.2.2 Canadian Interpretation of the Canada U.S. Tax Treaty

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...


Dual Resident Corporations

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.,...


Explanation and Interpretation of Article IV under U.S. Law

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 Commentary to the Fifth Protocol

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 U.S. interpretation of the Canada U.S Tax Treaty

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...















How to plan for dividend repatriation?

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...





Complexities of Limitations

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...


Income Limitations

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...


Excess Credit and Excess Limit

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...


What taxes are creditable?

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...



Cash Flow – Making Projections

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...


Cash Flow Statement

Cash Flow Statement It is a measure of how much cash a company has available or spent over a certain time period. An income statement does not provide a measure of cash generated....


Income Statement – Making Projections

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

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...


Income Statement

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...


Need for Financial Planning

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 Source Rules – U.S.A

Gross income comes from following categories of income: Interest, Dividends, Personal Services, Rentals, Royalties, Gains from disposition of property. Leasing generates rental income....


Saving Tax Dollars - Canada

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...


Importance of source of income rules

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 and items not included in income

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 - Canada

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...


Residency

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...


Retirement Savings and Profit Sharing Plans

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...


Definition of Resident Alien U.S.A

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...


Items not included in income - Canada

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...


Disclosure Requirements

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...



Items included in income - Canada

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...




Territorial and Credit System

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...


Transfer Pricing an Introduction

Multinational Companies do lot of intercompany transactions. U.S manufacturers market their products in foreign countries through their subsidiaries. Domestic parent companies sometimes...


Foreign Persons doing business in the United States

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...


U.S Investments of Foreign Persons

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...


Foreign Currency Transaction

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...


Foreign Tax Credit Deemd Paid - USA

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...


Foreign Tax Credit - USA

  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...


Source of Income Rules U.S.A

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...



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