IRS Amnesty Programs May Come To An End
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 […]
CRA Revised Sprinkling Proposals
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 […]
U.S. REPATRIATION TAX and GILTI TAX
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 […]
