Revised GILTI provisions under the Big Beautiful Bill
Changes to sections 250 and 960 have resulted in an increase in the tax burden to a CFC on active business income. GIVEN, for Ontario CCPCs, the 2025 the annual tax rate on active business income on the first $500K is about 12.2% due to the federal & Ontario Canadian small business deduction. Income above […]
U.S. Person Selling Canadian Principal Residence
A U.S. person say residing in Canada who files married separate their U.S. 1040 only can exclude $250K USD of their capital gain on the sale of their principal residence provided certain prescribed criteria is met. If the property was held more than a year, the maximum tax rate on long-term capital gain is 15% […]
Changes to Annual & Lifetime Gift Tax Exemption
For 2025, the annual exemption to a non- spouse is $19K and was not changed for 2026 by the Big & Beautiful Bill that passed in July 2025. The lifetime exemption is $13.99M for 2025 and $15M for 2026 due to the passing of the Big & Beautiful Bill. U.S. citizens or green card holders […]
