IRS Amnesty Programs May Come To An End

Posted by on Sep 18, 2018 in 2018 Articles | 0 comments

On September 4th, the IRS announced that the offshore voluntary disclosure program (“OVDP”) comes to an end on September 28, 2018, as announced in March 2018.
On September 4, 2018, the IRS reminded taxpayers that the streamlined programs often called the “Streamlined Foreign Offshore” program for those residing outside of the U.S. and the “Streamlined Domestic” program for those residing in the U.S., may also end.

Therefore as with the announcement in March 2018…

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CRA Revised Sprinkling Proposals

Posted by on Apr 16, 2018 in 2018 Articles | 0 comments

The “sprinkling” proposals issued in July 2017 were amended in December 2017 effective for the 2018 taxation year.
As you may recall, the July proposals were designed to tax at the top rate, individuals now over age 18 who are in receipt on what is called “split income” or TOSI (tax on split income). Before 2018, the TOSI was called a “kiddie tax”.
For 2018, the TOSI rules extend to family members who are…

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U.S. REPATRIATION TAX and GILTI TAX

Posted by on Apr 10, 2018 in 2018 Articles | 0 comments

On December 20, 2017 the “Tax Cuts and Jobs Act was passed in the United States.
CFC’s (controlled foreign corporations) or say Canadian corporations that are controlled by U.S. corporations, or by U.S. citizens or by green card holders will no longer have the luxury of deferring U.S. income tax on active business income. These are the most significant amendments to Subpart F of the Internal Revenue Code.
This transition tax is effective for 2017…

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