Canadian and US Tax Treaty

Total 20 Posts

Don’t Forget the T1141s and T1142s!

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Today’s Blog was written by Rahul Sharma, Partner, Fasken LLP, Toronto My last blog post was very early in the year.  In that post, I outlined — and generally responded to — certain common questions posed by newcomers to Canada.  As the year progresses, Canada continues to draw in large numbers of immigrants (with many more arrivals anticipated in the coming years).  For many newcomers, their first or second Canadian….

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Canada Revenue Agency, Canadian and US Tax Treaty, International, Tax Issues, Trusts, U.S. Citizen, Uncategorized, United States

Considerations when Administering a Canadian Estate with US Situs Assets

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Today’s blog is written by Jessica J. Butler, Law Clerk at Fasken LLP. As today’s world continues to grow increasingly interconnected, more estate professionals find themselves dealing with a web of cross-border assets and jurisdictional issues.  This post considers certain issues that you might face when administering a Canadian estate with assets situated in the United States. Legal Authority You must first determine whether you will need legal authority to….

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Canadian and US Tax Treaty, Estate Administration, International, IRS, Probate Tax, Tax Issues, United States, US Taxes, Wills

COVID Wedding Wars: Planning a Wedding During Yet Another Lockdown… or You Could Forget About It And Consider U.S. Estate Tax On U.S. Securities Held With Canadian Investment Dealers

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January is kickstarting what seems to be the “Year of the Hats” for me. In addition to my usual winter hat and estate planner hat, this month I’m also fashioning my wedding planner hat, COVID style.  As it turns out, planning a February wedding during a COVID lockdown actually means planning multiple backup weddings, each having their own contingency plan, guest list, and brand of potential disaster.  This has brought….

COVID Wedding Wars: Planning a Wedding During Yet Another Lockdown… or You Could Forget About It And Consider U.S. Estate Tax On U.S. Securities Held With Canadian Investment Dealers Continue Reading »

Canadian and US Tax Treaty, US Taxes

SHAREHOLDER REMUNERATION PLANNING

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Business owners-managers put money in and take money out on a regular basis during the year, and at the same time often use the business bank account for what may appear to be personal expenditures. This often leads to shareholder advance balances at year end and some major bookkeeping challenges to boot. These balances are often part of the consideration to determine shareholder bonuses and dividends at year-end, the characterization….

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Canada Revenue Agency, Canadian and US Tax Treaty, Estate Planning, Investments, IRS, Small Business, Tax Issues, Uncategorized

OFFSHORE ESTATE PLANNING AND MONEY TRANSFERS: A WORD OF CAUTION

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Just I am completing my personal income tax return and assisting many others with theirs, I continue to cling to the belief that most Canadians pay their fair shares of taxes. However, it appears many do not by “hiding” their money in offshore tax havens, sometimes under the guise of estate planning. There has been a lot of publicity in the past couple of years on how wealthy individuals around….

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Canada Revenue Agency, Canadian and US Tax Treaty, Estate Administration, Estate Planning, In the News, Investments, Tax Issues, Uncategorized

INCOME FROM A U.S. TRUST: CAN IT EVER BE TREATED AS DIVIDEND INCOME?

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Sometime ago, a relative of a Canadian taxpayer died in the US and she left her money in a charitable trust, with some of the income bequeathed to the Canadian taxpayer annually. The trust income is derived mostly from US dividends. With a series of proposed adjustments to her personal tax returns, the taxpayer asked the Canada Revenue agency (“CRA”) why this income could not be treated as dividend income….

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Canada Revenue Agency, Canadian and US Tax Treaty, Estate Administration, Estate Planning, Interest, Investments, Tax Issues, Trusts, United States, US Taxes
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