PRICE ADJUSTMENT CLAUSES IN ESTATE PLAN AGREEMENTS

Thursday, August 28th, 2014

Many estate plans include a transfer of property (e.g. shares of a privately held corporation) to a company and freeze the value (or price) of the transferred property to the current owners at the transfer date. To avoid some punitive provisions in the Income Tax Act associated with non-arm’s ...

US TAX FILING OBLIGATIONS FOR NON-RESIDENT US CITIZENS: SOME IRS RELIEF!

Tuesday, August 12th, 2014

Under most circumstances, citizens of the United States must file annual income tax returns regardless of residency. In 2012, the Internal Revenue Service (“IRS”) introduced 2 voluntary compliance programs to allow US citizens to comply with their income tax filing obligations thereby avoiding possible criminal prosecution and penalties: 1. the ...

Trust Income and Working Income Tax Benefit Eligibility

Thursday, July 24th, 2014

Recently the Canada Revenue Agency (“CRA”) was asked whether income allocated by a communal organization and reported as self employment earnings for CPP eligibility on a trust income tax slip (T3 slip) is considered “working” income for the recipient to claim the Working Income Tax Benefit (“WITB”). CRA responded that the ...