9.3.2 [a] Arm’s Length StandardArticle 9 incorporates into the Treaty the arm’s length principles reflected and noted above in U.S. domestic law. In its most basic dimensions,...
Posted by The Accounting and Tax on 12/05/2017
All homeowners should probably be aware of the term "basis". Basis is essentially the sum your house (or other similar property or investments such as stocks or mutual funds) is...
Posted by Advantage Tax Service on 11/22/2017
7.3.2 [a] Taxation of the Business Profits of a Canadian ResidentParagraph 1 of the Article VII of the Treaty provides that the business profits of a Canadian resident will only be...
Posted by The Accounting and Tax on 09/09/2017
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
7.2.2 [a] Article Vii[1]Business Profits – Taxation of Profits Attributable to a permanent EstablishmentBusiness profits of a U.S. resident carrying on a business in Canada are...
Posted by The Accounting and Tax on 08/31/2017
Generally, Article VII provides that the business profits of a person resident in one Contracting State should not be taxable in the other Contracting State unless the particular...
Posted by The Accounting and Tax on 08/31/2017
A major tax revenue for the majority of countries is courtesy wage income taxes via individual income and payroll taxes. Most industrialized nations have progressive income taxes,...
Posted by PB Tax & Accounting Services on 04/26/2017
A major tax revenue for the majority of countries is courtesy wage income taxes via individual income and payroll taxes. Most industrialized nations have progressive income taxes,...
Posted by CROMWELL & ASSOCIATES, LLC on 04/05/2017
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
