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Cross Border Taxation Services in Oakville & the GTA

Larry Stolberg | Certified Public Accountant | Chartered Professional Accountant

Tax consulting to financial advisors, lawyers, accounting firms and other professional advisors in the Halton, Wellington and Greater Toronto Area (GTA)

U.S. Tax Return Services

Detailed Tax Service | Estate Planning | Post Mortem Planning | Corporate Restructuring & Succession Planning | Partnership Restructuring | Immigration/Emigration Planning |

U.S. Tax Services

Resources

We have provided a comprehensive collection of resources which you can review. Contact your professional advisor prior to implementing any of the outlined strategies.FATCA legislation enhances discovery of delinquent US

IRS Rejects Canada FATCA Extension. Revised Streamlined Procedure!

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Tax Consulting
Tax consulting for you, or for accounting firms, lawyers, financial advisors or other professionalsI often assist other professionals with the more complex Canadian and U.S. tax issues affecting their clients.From corporate restructuring and estate planning to cross border and domestic compliance, these are just a few areas that I may become involved. You may click the “Services” tab at the top of the HOME PAGE and then scroll down to “Detailed Tax Services” for examples of various tax compliance and planning issues that I may deal with.My fees for services are competitive to that of the GTA area. I may invoice you or your client for a specific tax engagement, whatever you prefer. Initially, a retainer may be requested.I will take the lead on tax engagements, review with you all relevant facts and information. For example, a detailed instruction letter for you or your client’s lawyer may be provided, including a review of the legal documentation. If requested, CRA election forms will be provided. Where applicable, at your discretion, I may assist you in selecting a lawyer.

Compliance and Planning
I deal with various issues applying to individuals residing or working in either Canada or the United States.

General compliance work may include preparation of tax returns, personal, corporate, or trust/estate to filing notice of objections for appeals to the Canada Revenue Agency (“CRA”) or it my include just a simple planning consultation to get you on the right track.

From U.S. compliance for annual 1040 tax return filings for U.S. citizens/green card holders to IRS streamlined applications (catch-up), FBARs/FINCEN114, to expatriation, to businesses expanding/operating in either country, to Canadians or non-residents buying their first U.S./Canadian rental property to snowbirds , I can assist in the process. Moving to/or from Canada or to/from the U.S. is dealt with on a regular basis.

I am also an IRS Certified Acceptance Agent able to assist in obtaining an ITIN (individual taxpayer identification number).

Engagements for business owners and other interested parties

Including the tax services noted above, preparation of unaudited financial statements and Canadian corporate T2 or T1 personal tax returns to meet your compliance needs may be provided as well as dealing with CRA appeals/disputes and filing notices of objection. Corporation restructuring or determination if you qualify for investment tax credit for doing research & development is another possibility.

Please review the detailed services tab included in the “Services Tab” for additional services provided.

Tax Disputes
Tax Disputes and Appeals-CANADA & U.S.

Some of the routine areas that I may deal with are:

  • 1. Applying for our Canadian voluntary disclosure procedures to waive penalties and interest with respect to outstanding returns and prescribed forms
  • 2. Appealing your notice of (re)assessment to obtain a more favourable result where indicated.
  • 3. Dealing with collection officers to obtain reasonable payment terms and\or to remove liens and requirements to pay orders
  • 4. Meeting with officials to negotiate on your behalf U.S. streamlined & OVDP procedures for U.S. persons in respect to past-due tax returns, international information returns, FBARS (FINCEN114), etc.
Estate & Succession Planning
Estate & Succession Planning

I may deal with various techniques to minimize your otherwise potential tax burden arising on your passing. From assistance with WILL preparation, to corporate restructuring, to post-mortem planning or simply just to T1/T3 tax return preparation- I can assist in the process.

Succession planning in dealing with transfer of business to next generation is dealt with on a regular basis.

Corporate Reorganizations
Corporate Reorganizations

I deal with various restructuring options from estate planning, to purification to enhance the your ability to obtain the capital gains

exemption, to entry of family members or key employees as shareholders, to inter-generational farm transfers, to consolidation to simplify your present structure and reduce your annual fees, to access to small business deduction, to assistance with structuring a shareholders agreement & corporate-owned life insurance or even incorporation of professional corporations to that of proprietorships or partnerships-I can assist in the process.

Canada/U.S. Cross Border Compliance & Planning
Canada/U.S. Cross Border Compliance & Planning

I deal with various issues applying to individuals residing or working as employees or on a contractual basis in either Canada or the United States as well Canadian businesses or U.S. businesses wishing to expand into the other country. It is not unusual to get into a structure and find out latter that it is not only not tax effective but you have increased your annual compliance fees significantly. Cross border payments and domestic laws and TREATY application are an a important part of the analysis! Remember it is not always what you make, it is what you keep or retain. Repatriation of funds is an important element.

Cross border payments may include various types of income such as management fees, dividends, interest, royalties or pensions/annuities. In some situations, the Canada/U.S. tax treaty will exempt or reduce the U.S. 30% withholding tax. In this regard, you generally would require an IRS issued waiver form such as the W8-Ben. Sometimes you may need a U.S. ITIN. If tax is over withheld, you need to file a U.S. return to get the refund which can be avoided if you deal with the situation at the outset. Canada will not provide credit for excess withholding if it was due to you not claiming an available TREATY provision.

From U.S. compliance for annual foreign information returns to 1040 tax return filings for U.S. citizens/green card holders to IRS streamlined applications (catch-up), FBARs/FINCEN114, to expatriation, to Canadians or non-residents buying their first U.S./Canadian rental property and their 1040NR filings, to U.S. corporate (protective) filings because you are carrying on business in the U.S., I can assist in the process. Moving to/or from Canada or to/from the U.S. is dealt with on a regular basis.

Snowbirds

Canadians who wish to reside in the U.S. for the winter months should be aware of the U.S. residency rules. If you fall into these rules, you could be resident for U.S. income tax purposes and therefore be subject to U.S. tax on your world income unless you file the appropriate forms for exemptions.

Review the detailed article on Snowbirds contained in the Resources section-U.S. Taxation.

Inter-Generational Farm Transfers
Inter-generational farm transfers

I can help you with the transfer of farmland, quotas, equipment and shares of a family farm corporation.

Did you know that the Ontario Soil and Crop Improvement Association has a subsidy program to assist you with professional fees for succession planning. For an established farm business, they may finance 50% of the costs under the capacity building program. You may contact them at 1-800-265-97511-800-265-9751 FREE for additional information and/or access their website http://www.ontariosoilcrop.org/en/programs/growing_forward_2_new.htm

Please refer to my article in the Canadian Taxation Resources section at the top of the home page.

Professional Corporations
Professional Corporations

For a number of years, provincial governing bodies of regulated health professionals (1) and other professional organizations (2) have allowed the incorporation of the professional practice. The major tax advantage of incorporation, is the ability to defer tax by retaining income in the corporation that would otherwise be taxed at a much higher personal tax rate if you earned the same income as a sole proprietor or as a partner.

Refer to my article on professional corporations in the Canadian Taxation Resources section.

IRS ITIN Application
Effective  April 17, 2017 the IRS reinstated foreign or non-U.S. certified acceptance agents  that was disbanded on January 1, 2017.  Therefore I can now certify or if you wish, review your W-7 to ensure it is complete and accurate. A number of individuals have attempted to complete the W-7 themselves to which errors have arisen causing undue delays and months to successfully obtain an ITIN.  Note that with your self-prepared W-7 you will need to submit your original passport or obtain a certified copy of the passport from Passport Canada.  With certification, a photocopy of the passport will suffice.

If you are renting your U.S. real property via a management company or are listing for sale your U.S. property, you will need an ITIN. Canadian individual partners of a U.S. Limited Partnership will also need an ITIN. If you are only in receipt of say U.S. source income such as royalties, pension, dividends or interest that is not handled by a Canadian broker, the U.S. withholding agent may require you to have an ITIN.

Please refer to my articles in the resources section on U.S. Taxation, rental or sale of U.S. real property and the article in the services section on the ITIN.

Delinquent U.S. Individual Tax Filers
Delinquent U.S. individual tax filers

U.S. persons including U.S. citizens or green card holders residing in Canada who are not up to date with their U.S. filing obligations should consider the available programs in an effort to become tax-compliant.

The updated streamlined procedures announced on June 18, 2014 modified changes to the 2012 streamlined program, now known as the Streamlined Foreign Offshore Program (“SFOP”) requiring the filing of 3 years of past-due returns (with required disclosures and international information returns) plus 6 years of FBARs.

There were also modifications to the 2012 Offshore Voluntary Disclosure Program (“OVDP”) and a new streamlined procedure called Streamlined Domestic Offshore Program for U.S. persons residing in the United States.

Please refer to my article on Revised Streamlined Procedure in the resources section on U.S. taxation. The IRS website also has excellent information.

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