CANADIAN TAX ISSUES WITH CAPITAL DIVIDENDS AND NON-RESIDENT SHAREHOLDERS
Canadian International Tax Blog – Michael Atlas, CPA
by Michael Atlas
5y ago
Under the Income Tax Act (“the Act”) a “capital dividend” (“CD”)[1] paid by Canadian resident corporation is not included in the income of a recipient shareholder. A CD is an actual or deemed dividend paid with respect to which a specified election in prescribed form[2] has been filed by the paying corporation. A CD may […] The post CANADIAN TAX ISSUES WITH CAPITAL DIVIDENDS AND NON-RESIDENT SHAREHOLDERS appeared first on Michael Atlas, CPA ..read more
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HOW CANADIANS ARE SAVING TAX BY USING NON-CCPCs
Canadian International Tax Blog – Michael Atlas, CPA
by Michael Atlas
5y ago
For quite a few years now, many Canadians with substantial amounts of investment income and capital gains have been using private corporations that are not “Canadian-controlled private corporations” (“CCPCs) as a means of achieving substantial tax deferral. A CCPC will pay federal and provincial tax at a rate of about 50% on investment income (including […] The post HOW CANADIANS ARE SAVING TAX BY USING NON-CCPCs appeared first on Michael Atlas, CPA ..read more
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LLC “CHECKING THE BOX” MAY HAVE PITFALL FOR CANADIANS!
Canadian International Tax Blog – Michael Atlas, CPA
by Michael Atlas
5y ago
An answer to Question 16 of the “CRA Roundtable”, that was part of the 20th Annual STEP Canada Conference held earlier this year, may lead taxpayers and their advisor to make dangerously uninformed decisions. The question and answer are reproduced below:   “Given recent changes to the tax system in the US, Canadian resident persons […] The post LLC “CHECKING THE BOX” MAY HAVE PITFALL FOR CANADIANS! appeared first on Michael Atlas, CPA ..read more
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CRA CRACKING DOWN ON NON-RESIDENTS CLAIMING CCB
Canadian International Tax Blog – Michael Atlas, CPA
by Michael Atlas
5y ago
In the vast majority of cases where I advise individuals in connection with tax residency issues, it is with the objective of ensuring that they cease to be residents of Canada (or remain nonresidents, if they already are). Rarely is being resident in Canada for tax purposes beneficial. However, there are certain cases where a […] The post CRA CRACKING DOWN ON NON-RESIDENTS CLAIMING CCB appeared first on Michael Atlas, CPA ..read more
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BEWARE-THE CRA IS SCRUTINIZING CANADIANS WITH OFFSHORE TRUSTS
Canadian International Tax Blog – Michael Atlas, CPA
by Michael Atlas
5y ago
A recent lunch with a tax lawyer friend of mine gave me some valuable insights regarding how tough and aggressive the Canada Revenue Agency is getting with Canadians who report substantial distributions from offshore trusts. It also suggests that there are certain precautions that Canadians who are beneficiaries of offshore trusts should take in the […] The post BEWARE-THE CRA IS SCRUTINIZING CANADIANS WITH OFFSHORE TRUSTS appeared first on Michael Atlas, CPA ..read more
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HOW A CANADIAN HOLDCO CAN REDUCE TAXATION OF FAPI
Canadian International Tax Blog – Michael Atlas, CPA
by Michael Atlas
5y ago
As a general rule, every Canadian resident who is a shareholder of a “controlled foreign affiliate” (“CFA”), will be subject to tax in Canada on that person’s share of the “foreign accrual property income” (“FAPI”) of that CFA[1]. In general, the FAPI of the CFA will consist of income and taxable capital gains from investments. […] The post HOW A CANADIAN HOLDCO CAN REDUCE TAXATION OF FAPI appeared first on Michael Atlas, CPA ..read more
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RECENT FEDERAL COURT OF APPEAL DECISION MAY HELP CANADIAN TRUSTS WITH FOREIGN BENEFICIARIES  
Canadian International Tax Blog – Michael Atlas, CPA
by Michael Atlas
5y ago
In a recent article that I posted on this Blog (http://taxca.com/blog-2018-5/) (“Canadian Trusts with Foreign Beneficiaries Face New Challenges”), I discussed certain surprising statements that were made by the CRA at the 2017 Canadian Tax Foundation Annual Conference. It seems that they are suddenly alarmed about steps that tax planners have long used to allow […] The post RECENT FEDERAL COURT OF APPEAL DECISION MAY HELP CANADIAN TRUSTS WITH FOREIGN BENEFICIARIES   appeared first on Michael Atlas, CPA ..read more
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MOST OF CANADA’S TAX TREATIES WILL GET AN INSTANT REWRITE DUE TO MLI
Canadian International Tax Blog – Michael Atlas, CPA
by Michael Atlas
5y ago
On May 28, 2018, Canada’s Finance Minister tabled a Notice of Ways and Means Motion aimed at introducing legislation to enact the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting. This convention is commonly known as the “Multilateral Instrument”, or “MLI”. The MLI was signed by Canada on […] The post MOST OF CANADA’S TAX TREATIES WILL GET AN INSTANT REWRITE DUE TO MLI appeared first on Michael Atlas, CPA ..read more
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LITTLE-KNOWN PROVISION IN TREATY CAN ENSURE THAT AMERICANS GET FOREIGN TAX CREDIT FOR CANADIAN TAXES
Canadian International Tax Blog – Michael Atlas, CPA
by Michael Atlas
5y ago
The ability to claim credits for foreign taxes (“foreign tax credits”) (“FTC”) is the most fundamental and common way of avoiding double tax in connection with cross-border transactions. Both Canada and the U.S. have well-developed, and often complex, provisions within their tax laws to provide such credits where appropriate. Contrary to what many people think, […] The post LITTLE-KNOWN PROVISION IN TREATY CAN ENSURE THAT AMERICANS GET FOREIGN TAX CREDIT FOR CANADIAN TAXES appeared first on Michael Atlas, CPA ..read more
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CANADIAN FOREIGN ASSET REPORTING ISSUES WITH VACATION PROPERTIES
Canadian International Tax Blog – Michael Atlas, CPA
by Michael Atlas
5y ago
Thousands of Canadians own vacation properties in foreign jurisdictions, such as the United States, Mexico, Panama, or various Caribbean islands. With the winters in this country, that should be no surprise! Often there is confusion as to whether or not the ownership of such property needs to be reported to the Canada Revenue Agency (“CRA”) […] The post CANADIAN FOREIGN ASSET REPORTING ISSUES WITH VACATION PROPERTIES appeared first on Michael Atlas, CPA ..read more
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