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...
Posted by The Accounting and Tax on 07/03/2016
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.,...
Posted by The Accounting and Tax on 06/09/2016
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...
Posted by The Accounting and Tax on 06/09/2016
For small businesses that have chosen to incorporate, there are some unique aspects to consider when it comes to the taxes that your corporation will pay on capital gains. Capital...
Posted by Joseph J. Gormley CPA on 06/09/2016
For a variety of businesses that have chosen to incorporate, there are some unique aspects to consider when it comes to the taxes that your corporation will pay on capital gains, which...
Posted by Horizon Client Services, LLC on 06/09/2016
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...
Posted by The Accounting and Tax on 06/09/2016
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...
Posted by The Accounting and Tax on 06/09/2016
Investors do not typically choose their investments based on their potential tax liability. However, during the tax filing season, all your investments and dividends will now play...
Posted by ERNIE BUSTAMANTE on 04/25/2016
Starting a new business can be an exciting time in your life. You have put a lot of time and energy into the business and you want to make sure that you have it all in order. One of...
Posted by BTL & Company, P C, Tax & Accounting on 04/10/2016
