6.1 IntroductionArticle VI (Income from Real Property) affirms the jurisdictional powers of the source State to impose its income tax on income derived by the resident of the residence...
Posted by The Accounting and Tax on 07/19/2016
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
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
5.2.2[a] Article V(1) – Definition of Permanent EstablishmentArticle V (1) provides a general concept of the notion of “permanent establishment” for the purposes of the Treaty.For...
Posted by The Accounting and Tax on 06/21/2016
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
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
Foreign Persons doing Business in the United States...
Posted by The Accounting and Tax on 03/27/2016
For many homeowners, property taxes are a fact of life. If you own a second home or vacation home, then you have property taxes for that property as well. These properties can be subjected...
Posted by Allan J Rolnick, CPA, CTC on 03/27/2016
