/Cross Border Tax Planning

Cross Border Tax Planning

11 02, 2014

Advisor.ca – Tax benefits of an estate freeze

David A. Altro and Jonah Z. Spiegelman recently co-authored an article which appeared on Advisor.ca and is scheduled to appear in the March or April 2014 edition of Advisor’s Edge magazine. In the article, David and Jonah explain the tax benefits of an estate freeze, which is a follow up piece on David’s recent article [...]

14 01, 2014

The Far Reach of FATCA

I spent five glorious months of my law school career on exchange in L.A. I loved living in California: when the “winter” came, I couldn’t believe how warm it was. I drove to class every day with my sunroof open and palm trees gracing the sky above me. I got myself a cute little apartment in [...]

7 11, 2013

Canadian Income Splitting and Issues for Americans

On October 1, 2013, the Canada Revenue Agency (“CRA”) increased the prescribed interest rate to 2%. This change clearly affects Canadians looking to use prescribed rate loans as a strategy for income splitting, but prescribed rate loans used for income splitting purposes can also affect US citizens, US residents and even green card holders (collectively referred [...]

2 10, 2013

US Government Shutdown – What it Means for Canadians

As of 12 am October 1, 2013, the US government “shutdown” due to a lack of budget. It is the role of Congress to prepare and pass a spending bill, also known as a budget, prior to the start of each fiscal year. The US government’s fiscal year runs from October 1st to September 30th, hence [...]

24 09, 2013

US taxpayers with RRSPs? File now to avoid penalties!

As cross border tax advisors, we routinely meet with American citizens who have lived in Canada for many years without understanding their tax obligations in the US. A similarly complex situation may arise for Canadian citizens who have moved to the US for work or retirement. Even those who are compliant with the income tax filings [...]

18 09, 2013

Putting the LLC Debate to Rest

Canadians are still running to the US in hopes of yielding a higher rate of return by investing their hard earned money across the border. Many of these investments include US real estate, whether it is a multitude of rental properties, one for personal use by the family or simply for retirement. No matter what your [...]

26 08, 2013

Is a Limited Liability Company (LLC) good for Canadians buying in the U.S.?

If you are Canadian, the answer to that question is: it depends. People purchasing real estate in the U.S. are faced with different challenges depending on whether they plan on using the property personally or renting it. In this article, we will address the latter issue and its different implications. A Tax Efficient Structure There are [...]

3 07, 2013

Branch or Subsidiary: Tax Planning for CDN Companies Expanding Operations to the US

Canadian businesses looking to expand operations into the US have many issues to work through at the planning stage, and one important one is how to structure US operations from a tax perspective. This post discusses some of the considerations to keep in mind when deciding between forming a US subsidiary or operating directly in the [...]

28 06, 2013

Update: US Senate Votes to Approve Gang of Eight’s US Immigration Reform Bill

Yesterday afternoon the US Senate voted to approve the US Immigration Reform Bill with a final vote of 68-32 in favor of the bill. While some modifications to the bill were made in the Senate, the key provisions for Canadians have remained largely untouched. These key provisions include Canadian/ Snowbird Tourism, and the US Retiree visa. [...]

12 06, 2013

The New U.S. Immigration Bill – Impacts to Canadians Spending More Time in the U.S.

In recent weeks, there has been extensive news coverage on the Gang of Eight’s U.S. Immigration reform bill. If the new bill were to pass, U.S. Immigration (USCIS) would extend the amount of days a Canadian can spend in the U.S. from 180 to 240 per year. Many Canadian Snowbirds are delighted that their 6-month sunny [...]