11.3 Explanation & Interpretation of Article XI under U.S. Law 11.3.1 U.S Domestic Taxation of Interest Paid to Canadian Residents11.3.1[a] Definition of InterestInterest...
Posted by The Accounting and Tax on 06/25/2018
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
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
Many small business owners often wonder if there is a benefit to incorporating their business. Yet by incorporating your business, you can receive several tax benefits to reduce your...
Posted by Shabnam Merali on 03/23/2016
Rules for determination of amount, timing, character and source of foreign currency gains and loss are present in code section 988. Following transactions are included in code section...
Posted by The Accounting and Tax on 01/28/2016
Currency translation issues:Foreign branches and subsidiaries keep their books and records in the currency of host country.Parent companies in USA are required to compute their taxable...
Posted by The Accounting and Tax on 01/27/2016
For many investors that buy stocks in corporations, they have often found themselves in receipt of dividends on a quarterly or annual basis. However, there are several different...
Posted by Denisha Marino on 01/22/2016
USA will only tax foreign business earnings if it repatriates it to USA through dividends. This policy is known as “deferral”. Deferral creates an opportunity for avoiding...
Posted by The Accounting and Tax on 01/10/2016
A general rule for tax planning for dividend repatriation includes cross-crediting, minimizing foreign withholding taxes and considering alternative methods of repatriating earnings. Cross-Crediting If...
Posted by The Accounting and Tax on 01/06/2016
