This blog has been written by Rahul Sharma, Partner at Fasken LLP A couple of recent telephone calls reminded me of the perils of estate and tax planning that crosses borders without proper planning. The first case is regrettably quite common. An entrepreneur in the technology sector (we will call…
Category: U.S. Citizen
Total 25 Posts
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…
The 2020 U.S. election is over and the votes have been tabulated, and in some counties the votes have even been tabulated more than once. Unless there is some Republican wild card waiting to be plucked out of the proverbial magic hat, then Joe Biden will be inaugurated president of…
Who owns the rights to a celebrity’s image after death? Do these rights pass automatically to the celebrity’s estate? How are these rights protected?
With TIFF in full swing, celebrity worship is in overdrive. However, celebrities also deal with the mundane and there is often nothing glamorous about their estates. In fact, like the rest of us mere mortals, celebrities do not have a lock on getting things right. So often, there is so…
In today’s world of international families it is not uncommon for a Canadian family to have one or more members that are non-residents of Canada. When that same family has set up a Canadian discretionary family trust that is intended to benefit its members with, say distributions from a family…
“Yesterday, we lost a giant – an exceptionally creative scientist and engineer who was also a delightful human being. Millie Dresselhaus began life as the child of poor Polish immigrants in the Bronx; by the end, she was Institute Professor Emerita, the highest distinction awarded by the MIT faculty. A…
This year’s STEP conference featured over 65 speakers including for the very first time, the IRS spoke on Canadian soil about offshore compliance options including OVDP and streamlined compliance procedures.
Like many countries rules for being a citizen, an individual is a US citizen either because they were born in the United States or because they have become a citizen through the process of naturalization. Either way, once a US citizen you are entitled to the rights, privileges and benefits of being a US citizen. One of those privileges is the right to acquire a US passport.
Subject to the relevant sections of the Income Tax Act, a Canadian private corporation has a special corporate tax account known as a capital dividend account (“CDA”) which gives shareholders designated capital dividends, tax free. The CDA of a corporation may include the non-taxable portion of the company’s capital gains,…