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
Tax season brings on serious stress and frustration for many business owners, and it's understandable when the tax preparation isn't going as smoothly as you hope or the numbers aren't...
Posted by Advantage Tax Service on 11/08/2017
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
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
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
IntroductionThis article of the treaty talks about following points:1 – The business profits of a resident of a Contracting State shall be taxable only in the State unless the...
Posted by The Accounting and Tax on 08/31/2017
When preparing your tax return, you have to choose between standard deductions and itemized deductions. Your choice would likely depend on the higher figure, which is what most taxpayers...
Posted by ICHIBAN INTL., INC. dba US-Taxman on 05/17/2017
