Improving offshore compliance has been a top priority of the Internal Revenue Service (IRS) for some time now. Because of this, people's ability to avoid detection is almost impossible,...
Posted by Omni Fidelity Associates on 02/08/2018
7.3.1 [a] U.S. Taxation of Income of Foreign PersonsForeign persons generating income from U.S. sources are potentially subject to one, or both, of two U.S. federal taxation regimes....
Posted by The Accounting and Tax on 09/09/2017
7 . 2 . 1 (a)In general, the net business profits of a non-resident carrying on business or any other income generating activities in Canada are subject to the income tax imposed under...
Posted by The Accounting and Tax on 08/31/2017
6.3.1 Taxation of Investments in U.S Real Property by Canadian Investors6.3.1 (a) - IntroductionThere are many tax and legal considerations that must be weighed before making an investment...
Posted by The Accounting and Tax on 07/28/2016
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
When a small business owner is looking for a way to expand into their business, they may look for avenues where their industry has not yet made a name for themselves. However, many...
Posted by James Wells EA MBA Tax Office on 06/25/2016
5.2.1[a] Taxation of Income of Non-Residents GenerallyA non-resident person is subject to Part I tax in Canada if the non-resident, at any time in a taxation year,1 – Was employed...
Posted by The Accounting and Tax on 06/21/2016
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
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
