The document summarizes 2010 cross-border tax updates for the US and Canada. On the US side, it discusses PFIC reporting requirements, foreign bank account reporting, tax rate changes including the healthcare bill, and the voluntary disclosure process. For Canada, it covers foreign tax credit generators, taxable Canadian property rule changes, tax avoidance transactions, and stock option changes. Quebec may serve as a model for federal tax changes.
Speeding Through 2020 Auto Webinar Series - Year-End ReviewCitrin Cooperman
As 2020 nears completion, we discuss what automotive dealerships need to record and what files need to be kept in order to ensure that 2020 is closed properly and that the new year starts off right.
Jimmy Gentry presents "SEC Filings" during the Reynolds Center for Business Journalism's annual Business Journalism Week, Jan. 2, 2014. Gentry is the Clyde M. Reed Teaching Professor at the University of Kansas' School of Journalism and Mass Communications.
The annual event features two concurrent seminars, Business Journalism Professors and Strictly Financials for journalists.
For more information about business journalism training, please visit http://businessjournalism.org.
Jimmy Gentry presents "Securities and Exchange Commission Filings" during the Reynolds Center for Business Journalism's annual Business Journalism Week, Jan. 4, 2014. Gentry is the Clyde M. Reed Teaching Professor at the University of Kansas' School of Journalism and Mass Communications.
The annual event features two concurrent seminars, Business Journalism Professors and Strictly Financials for journalists.
For more information about business journalism training, please visit http://businessjournalism.org.
After repeal of ETI exclusion, the IC-DISC is the only option available to obtain export tax benefits. Most companies can increase their after-tax cash flow by incorporating an IC-DISC. IC-DISC structure takes advantage of the 15% tax rate on dividends
Speeding Through 2020 Auto Webinar Series - Year-End ReviewCitrin Cooperman
As 2020 nears completion, we discuss what automotive dealerships need to record and what files need to be kept in order to ensure that 2020 is closed properly and that the new year starts off right.
Jimmy Gentry presents "SEC Filings" during the Reynolds Center for Business Journalism's annual Business Journalism Week, Jan. 2, 2014. Gentry is the Clyde M. Reed Teaching Professor at the University of Kansas' School of Journalism and Mass Communications.
The annual event features two concurrent seminars, Business Journalism Professors and Strictly Financials for journalists.
For more information about business journalism training, please visit http://businessjournalism.org.
Jimmy Gentry presents "Securities and Exchange Commission Filings" during the Reynolds Center for Business Journalism's annual Business Journalism Week, Jan. 4, 2014. Gentry is the Clyde M. Reed Teaching Professor at the University of Kansas' School of Journalism and Mass Communications.
The annual event features two concurrent seminars, Business Journalism Professors and Strictly Financials for journalists.
For more information about business journalism training, please visit http://businessjournalism.org.
After repeal of ETI exclusion, the IC-DISC is the only option available to obtain export tax benefits. Most companies can increase their after-tax cash flow by incorporating an IC-DISC. IC-DISC structure takes advantage of the 15% tax rate on dividends
Jimmy Gentry presents "SEC Documents" during Reynolds Business Journalism Week 2013.
Reynolds Business Journalism Week is an all-expenses-paid seminar for journalists looking to enhance their business coverage, and professors looking to enhance or create business journalism courses.
For more information about business journalism training, please visit businessjournalism.org.
This presentation serves as study notes for the e-learning material titled: "South African Hedge funds and international developments"
These notes focus on FATCA and its Impact on the Hedge Fund Industry.
http://www.hedgefund-sa.co.za/fatca
This workshop helps attendees understand the income taxation of trusts and estates, identify sources of taxable income, calculate distributable net income, and apply the Alternative Minimum Tax.
Presenter: David Spence, Jennifer Han, Allison Kroeker, and Li (Fiona) Xu of Royse Law Firm
CTKnowledgeShare: CT Corporation is dedicated to educating our customers on the most current and essential topics for corporate legal and compliance professionals.
This was a presentation to NJTC audience - a Government delegation on Financial Innovation & Supervision, with Tax Evasion, Tax Transparency and how FATCA, CRS solutions addresses tax transparency.
This is Part 1 of a slide deck was presented by the University of Illinois Tax School in conjunction with a textbook entitled Limited Liability Companies: Electing Partnership vs. S Corporation Status. The presentation gives good background on various LLC topics (such as LLC formation, LLC operations, Distributions of an LLC, Sale of a Member Interest, Withdrawal of a Member, and Death of a Member). The textbook itself can be purchased at https://taxschool.illinois.edu/.
The first seminar of a four-part series on growing a business and preparing it for sale led by the co-chair of Kegler Brown's M+A practice, Eric Duffee. Eric partnered with Jeff Tubaugh and Maggie Gilmore of BDO for this presentation, which focused on the fundamentals of entity selection. It detailed different entity types and the related impacts from tax reform affecting them. It also discussed concerns related to outside investors, partnerships, various structural forms and the tax impact of each.
Jimmy Gentry presents "SEC Documents" during Reynolds Business Journalism Week 2013.
Reynolds Business Journalism Week is an all-expenses-paid seminar for journalists looking to enhance their business coverage, and professors looking to enhance or create business journalism courses.
For more information about business journalism training, please visit businessjournalism.org.
This presentation serves as study notes for the e-learning material titled: "South African Hedge funds and international developments"
These notes focus on FATCA and its Impact on the Hedge Fund Industry.
http://www.hedgefund-sa.co.za/fatca
This workshop helps attendees understand the income taxation of trusts and estates, identify sources of taxable income, calculate distributable net income, and apply the Alternative Minimum Tax.
Presenter: David Spence, Jennifer Han, Allison Kroeker, and Li (Fiona) Xu of Royse Law Firm
CTKnowledgeShare: CT Corporation is dedicated to educating our customers on the most current and essential topics for corporate legal and compliance professionals.
This was a presentation to NJTC audience - a Government delegation on Financial Innovation & Supervision, with Tax Evasion, Tax Transparency and how FATCA, CRS solutions addresses tax transparency.
This is Part 1 of a slide deck was presented by the University of Illinois Tax School in conjunction with a textbook entitled Limited Liability Companies: Electing Partnership vs. S Corporation Status. The presentation gives good background on various LLC topics (such as LLC formation, LLC operations, Distributions of an LLC, Sale of a Member Interest, Withdrawal of a Member, and Death of a Member). The textbook itself can be purchased at https://taxschool.illinois.edu/.
The first seminar of a four-part series on growing a business and preparing it for sale led by the co-chair of Kegler Brown's M+A practice, Eric Duffee. Eric partnered with Jeff Tubaugh and Maggie Gilmore of BDO for this presentation, which focused on the fundamentals of entity selection. It detailed different entity types and the related impacts from tax reform affecting them. It also discussed concerns related to outside investors, partnerships, various structural forms and the tax impact of each.
The 440 page LexisNexis® Guide to FATCA Compliance was designed in consultation, via numerous interviews and meetings, with government officials, NGO staff, large financial institution compliance officers, investment fund compliance officers, and trust companies, from North and South America, Europe, South Africa, and Asia, and in consultation with contributors who are leading industry experts. The contributors hail from several countries and an offshore financial center and include attorneys, accountants, information technology engineers, and risk managers from large, medium and small firms and from large financial institutions. Thus, the challenges of the FATCA Compliance Officer are approached from several perspectives and contextual backgrounds. See http://www.lexisnexis.com/store/catalog/booktemplate/productdetail.jsp?pageName=relatedProducts&prodId=prod19190327
This 28 chapter Guide contains three chapters written specifically to guide a financial institution's lead FATCA compliance officer in designing a plan of internal action within the enterprise and interaction with outside FATCA advisors with a view of best leveraging available resources and budget [see Chapters 2, 3, and 4]. Sample chapter available at http://www.lexisnexis.com/store/images/samples/9780769853734.pdf
International Tax Reform for US Individuals and Pass-through Entities Fenwick & West
The recent Tax Cuts and Jobs Act has revolutionized the U.S. taxation of international income earned from outbound investment and business operations. While enacted to rationalize the taxation of U.S.-based multinational corporations, these rules have an even more dramatic effect on non-corporate U.S. shareholders of controlled foreign corporations, such as individuals, trusts, S corporations and partnerships. These slides, which were originally presented as part of a Strafford group webinar, provide an overview of GILTI as applied to a non-corporate U.S. shareholder, interaction with Section 962, and review of other international tax reform changes relevant to individual shareholders in foreign businesses.
2018 Pennsylvania Tax Update: The State Budget, Legislation, and Multistate T...McKonly & Asbury, LLP
This webinar was hosted by McKonly & Asbury Senior Tax Manager and SALT Leader, Michael Eby, and Tax Supervisor, Lindsey Waltemyer.
It provides an overview of the enacted 2017-2018 Pennsylvania State Budget; a brief update on recently passed Pennsylvania tax legislation and court decisions of interest; and discusses how states, including Pennsylvania, are addressing these changes at the Federal level in their own respective tax structure.
California Incentives and Multi-State Tax Issues webinar slidesRoger Royse
An online discussion of various state tax issues for companies and individuals doing business in California. Our panelists cover recent developments in California income and sales tax, tax credits and incentives, multi-state tax issues for technology companies and state residency planning for individuals. Our panel of speakers includes:
Roger Royse, Royse Law Firm
Monika Miles, Miles Consulting Group
David Wittrock, Price, Wittrock CPA LLP
David Spence, Royse Law Firm
This is the first half of a presentation I gave at Pace University Law School's Program: New Directions: Practical Skills for Returning to Law Practice
http://web.pace.edu/page.cfm?doc_id=29130
Tax Foundation University 2017, Part 1: Why Tax Reform? Why Now? Why Not Just...Tax Foundation
This presentation reviews key considerations in tax reform – balancing revenues, growth, and tax equity.
Charts describe the current tax system, its general framework, progressive structure, complexity, biases, and distorting features.
It also explores who pays taxes, and how markets shift the tax burden.
In general terms, this is one of the most frequent questions we get from prospective clients. So then, How do you file US tax returns while in Canada?
The first question we need to ask is whether you’re actually required to file US tax returns. Generally speaking, US citizens and Green Card holders are required to file US tax returns regardless of where they live. Therefore Americans living in Canada, whether they’ve recently moved to Canada or have been in the country their entire lives are required to file US tax returns in addition to their regular Canadian tax returns.
Impact of TCJA,TCJATCJATCJATCJATCJATCJATCJATCJATCJAtradingwork567
Impact of TCJAImpact of TCJAImpact of TCJAImpact of TCJAImpact of TCJAImpact of TCJAImpact of TCJAImpact of TCJAImpact of TCJAImpact of TCJAImpact of TCJAImpact of TCJAImpact of TCJAImpact of TCJAImpact of TCJAImpact of TCJAImpact of TCJAImpact of TCJAImpact of TCJAImpact of TCJAImpact of TCJAImpact of TCJAImpact of TCJAImpact of TCJAImpact of TCJAImpact of TCJAImpact of TCJAImpact of TCJAImpact of TCJAImpact of TCJAImpact of TCJAImpact of TCJAImpact of TCJAImpact of TCJAImpact of TCJAImpact of TCJA
The Evolution of Non-Banking Financial Companies (NBFCs) in India: Challenges...beulahfernandes8
Role in Financial System
NBFCs are critical in bridging the financial inclusion gap.
They provide specialized financial services that cater to segments often neglected by traditional banks.
Economic Impact
NBFCs contribute significantly to India's GDP.
They support sectors like micro, small, and medium enterprises (MSMEs), housing finance, and personal loans.
The secret way to sell pi coins effortlessly.DOT TECH
Well as we all know pi isn't launched yet. But you can still sell your pi coins effortlessly because some whales in China are interested in holding massive pi coins. And they are willing to pay good money for it. If you are interested in selling I will leave a contact for you. Just telegram this number below. I sold about 3000 pi coins to him and he paid me immediately.
Telegram: @Pi_vendor_247
Introduction to Indian Financial System ()Avanish Goel
The financial system of a country is an important tool for economic development of the country, as it helps in creation of wealth by linking savings with investments.
It facilitates the flow of funds form the households (savers) to business firms (investors) to aid in wealth creation and development of both the parties
Financial Assets: Debit vs Equity Securities.pptxWrito-Finance
financial assets represent claim for future benefit or cash. Financial assets are formed by establishing contracts between participants. These financial assets are used for collection of huge amounts of money for business purposes.
Two major Types: Debt Securities and Equity Securities.
Debt Securities are Also known as fixed-income securities or instruments. The type of assets is formed by establishing contracts between investor and issuer of the asset.
• The first type of Debit securities is BONDS. Bonds are issued by corporations and government (both local and national government).
• The second important type of Debit security is NOTES. Apart from similarities associated with notes and bonds, notes have shorter term maturity.
• The 3rd important type of Debit security is TRESURY BILLS. These securities have short-term ranging from three months, six months, and one year. Issuer of such securities are governments.
• Above discussed debit securities are mostly issued by governments and corporations. CERTIFICATE OF DEPOSITS CDs are issued by Banks and Financial Institutions. Risk factor associated with CDs gets reduced when issued by reputable institutions or Banks.
Following are the risk attached with debt securities: Credit risk, interest rate risk and currency risk
There are no fixed maturity dates in such securities, and asset’s value is determined by company’s performance. There are two major types of equity securities: common stock and preferred stock.
Common Stock: These are simple equity securities and bear no complexities which the preferred stock bears. Holders of such securities or instrument have the voting rights when it comes to select the company’s board of director or the business decisions to be made.
Preferred Stock: Preferred stocks are sometime referred to as hybrid securities, because it contains elements of both debit security and equity security. Preferred stock confers ownership rights to security holder that is why it is equity instrument
<a href="https://www.writofinance.com/equity-securities-features-types-risk/" >Equity securities </a> as a whole is used for capital funding for companies. Companies have multiple expenses to cover. Potential growth of company is required in competitive market. So, these securities are used for capital generation, and then uses it for company’s growth.
Concluding remarks
Both are employed in business. Businesses are often established through debit securities, then what is the need for equity securities. Companies have to cover multiple expenses and expansion of business. They can also use equity instruments for repayment of debits. So, there are multiple uses for securities. As an investor, you need tools for analysis. Investment decisions are made by carefully analyzing the market. For better analysis of the stock market, investors often employ financial analysis of companies.
how can I sell pi coins after successfully completing KYCDOT TECH
Pi coins is not launched yet in any exchange 💱 this means it's not swappable, the current pi displaying on coin market cap is the iou version of pi. And you can learn all about that on my previous post.
RIGHT NOW THE ONLY WAY you can sell pi coins is through verified pi merchants. A pi merchant is someone who buys pi coins and resell them to exchanges and crypto whales. Looking forward to hold massive quantities of pi coins before the mainnet launch.
This is because pi network is not doing any pre-sale or ico offerings, the only way to get my coins is from buying from miners. So a merchant facilitates the transactions between the miners and these exchanges holding pi.
I and my friends has sold more than 6000 pi coins successfully with this method. I will be happy to share the contact of my personal pi merchant. The one i trade with, if you have your own merchant you can trade with them. For those who are new.
Message: @Pi_vendor_247 on telegram.
I wouldn't advise you selling all percentage of the pi coins. Leave at least a before so its a win win during open mainnet. Have a nice day pioneers ♥️
#kyc #mainnet #picoins #pi #sellpi #piwallet
#pinetwork
What website can I sell pi coins securely.DOT TECH
Currently there are no website or exchange that allow buying or selling of pi coins..
But you can still easily sell pi coins, by reselling it to exchanges/crypto whales interested in holding thousands of pi coins before the mainnet launch.
Who is a pi merchant?
A pi merchant is someone who buys pi coins from miners and resell to these crypto whales and holders of pi..
This is because pi network is not doing any pre-sale. The only way exchanges can get pi is by buying from miners and pi merchants stands in between the miners and the exchanges.
How can I sell my pi coins?
Selling pi coins is really easy, but first you need to migrate to mainnet wallet before you can do that. I will leave the telegram contact of my personal pi merchant to trade with.
Tele-gram.
@Pi_vendor_247
BYD SWOT Analysis and In-Depth Insights 2024.pptxmikemetalprod
Indepth analysis of the BYD 2024
BYD (Build Your Dreams) is a Chinese automaker and battery manufacturer that has snowballed over the past two decades to become a significant player in electric vehicles and global clean energy technology.
This SWOT analysis examines BYD's strengths, weaknesses, opportunities, and threats as it competes in the fast-changing automotive and energy storage industries.
Founded in 1995 and headquartered in Shenzhen, BYD started as a battery company before expanding into automobiles in the early 2000s.
Initially manufacturing gasoline-powered vehicles, BYD focused on plug-in hybrid and fully electric vehicles, leveraging its expertise in battery technology.
Today, BYD is the world’s largest electric vehicle manufacturer, delivering over 1.2 million electric cars globally. The company also produces electric buses, trucks, forklifts, and rail transit.
On the energy side, BYD is a major supplier of rechargeable batteries for cell phones, laptops, electric vehicles, and energy storage systems.
If you are looking for a pi coin investor. Then look no further because I have the right one he is a pi vendor (he buy and resell to whales in China). I met him on a crypto conference and ever since I and my friends have sold more than 10k pi coins to him And he bought all and still want more. I will drop his telegram handle below just send him a message.
@Pi_vendor_247
Even tho Pi network is not listed on any exchange yet.
Buying/Selling or investing in pi network coins is highly possible through the help of vendors. You can buy from vendors[ buy directly from the pi network miners and resell it]. I will leave the telegram contact of my personal vendor.
@Pi_vendor_247
What price will pi network be listed on exchangesDOT TECH
The rate at which pi will be listed is practically unknown. But due to speculations surrounding it the predicted rate is tends to be from 30$ — 50$.
So if you are interested in selling your pi network coins at a high rate tho. Or you can't wait till the mainnet launch in 2026. You can easily trade your pi coins with a merchant.
A merchant is someone who buys pi coins from miners and resell them to Investors looking forward to hold massive quantities till mainnet launch.
I will leave the telegram contact of my personal pi vendor to trade with.
@Pi_vendor_247
what is the best method to sell pi coins in 2024DOT TECH
The best way to sell your pi coins safely is trading with an exchange..but since pi is not launched in any exchange, and second option is through a VERIFIED pi merchant.
Who is a pi merchant?
A pi merchant is someone who buys pi coins from miners and pioneers and resell them to Investors looking forward to hold massive amounts before mainnet launch in 2026.
I will leave the telegram contact of my personal pi merchant to trade pi coins with.
@Pi_vendor_247
how to sell pi coins at high rate quickly.DOT TECH
Where can I sell my pi coins at a high rate.
Pi is not launched yet on any exchange. But one can easily sell his or her pi coins to investors who want to hold pi till mainnet launch.
This means crypto whales want to hold pi. And you can get a good rate for selling pi to them. I will leave the telegram contact of my personal pi vendor below.
A vendor is someone who buys from a miner and resell it to a holder or crypto whale.
Here is the telegram contact of my vendor:
@Pi_vendor_247
US Economic Outlook - Being Decided - M Capital Group August 2021.pdfpchutichetpong
The U.S. economy is continuing its impressive recovery from the COVID-19 pandemic and not slowing down despite re-occurring bumps. The U.S. savings rate reached its highest ever recorded level at 34% in April 2020 and Americans seem ready to spend. The sectors that had been hurt the most by the pandemic specifically reduced consumer spending, like retail, leisure, hospitality, and travel, are now experiencing massive growth in revenue and job openings.
Could this growth lead to a “Roaring Twenties”? As quickly as the U.S. economy contracted, experiencing a 9.1% drop in economic output relative to the business cycle in Q2 2020, the largest in recorded history, it has rebounded beyond expectations. This surprising growth seems to be fueled by the U.S. government’s aggressive fiscal and monetary policies, and an increase in consumer spending as mobility restrictions are lifted. Unemployment rates between June 2020 and June 2021 decreased by 5.2%, while the demand for labor is increasing, coupled with increasing wages to incentivize Americans to rejoin the labor force. Schools and businesses are expected to fully reopen soon. In parallel, vaccination rates across the country and the world continue to rise, with full vaccination rates of 50% and 14.8% respectively.
However, it is not completely smooth sailing from here. According to M Capital Group, the main risks that threaten the continued growth of the U.S. economy are inflation, unsettled trade relations, and another wave of Covid-19 mutations that could shut down the world again. Have we learned from the past year of COVID-19 and adapted our economy accordingly?
“In order for the U.S. economy to continue growing, whether there is another wave or not, the U.S. needs to focus on diversifying supply chains, supporting business investment, and maintaining consumer spending,” says Grace Feeley, a research analyst at M Capital Group.
While the economic indicators are positive, the risks are coming closer to manifesting and threatening such growth. The new variants spreading throughout the world, Delta, Lambda, and Gamma, are vaccine-resistant and muddy the predictions made about the economy and health of the country. These variants bring back the feeling of uncertainty that has wreaked havoc not only on the stock market but the mindset of people around the world. MCG provides unique insight on how to mitigate these risks to possibly ensure a bright economic future.
how to swap pi coins to foreign currency withdrawable.DOT TECH
As of my last update, Pi is still in the testing phase and is not tradable on any exchanges.
However, Pi Network has announced plans to launch its Testnet and Mainnet in the future, which may include listing Pi on exchanges.
The current method for selling pi coins involves exchanging them with a pi vendor who purchases pi coins for investment reasons.
If you want to sell your pi coins, reach out to a pi vendor and sell them to anyone looking to sell pi coins from any country around the globe.
Below is the contact information for my personal pi vendor.
Telegram: @Pi_vendor_247
Empowering the Unbanked: The Vital Role of NBFCs in Promoting Financial Inclu...Vighnesh Shashtri
In India, financial inclusion remains a critical challenge, with a significant portion of the population still unbanked. Non-Banking Financial Companies (NBFCs) have emerged as key players in bridging this gap by providing financial services to those often overlooked by traditional banking institutions. This article delves into how NBFCs are fostering financial inclusion and empowering the unbanked.
How to get verified on Coinbase Account?_.docxBuy bitget
t's important to note that buying verified Coinbase accounts is not recommended and may violate Coinbase's terms of service. Instead of searching to "buy verified Coinbase accounts," follow the proper steps to verify your own account to ensure compliance and security.
2. 2
Topic summary
US tax update:
PFIC update – reporting
Foreign Bank Account reporting
Tax rate changes
Voluntary Declaration process update
CFC update
Miscellaneous legislation
Canadian tax update:
Foreign tax credit generators
Taxable Cdn property rule changes
Tax avoidance transactions
Stock option changes
Quebec - model for Feds?
3. PFIC
Passive Foreign Investment Company
(PFIC) Update
PFIC shareholder must file annual return
Previously only when taxable event occurred or election
made
Statute of limitations suspended INDEFINITELY
for failure to file annual return
Further, the statute of limitations is suspended
INDEFINITELY for failure to file ANY informational
return (recently clarified)
4. PFIC
What is a PFIC?
Canadian mutual funds – trusts v. corporation
If trust for U.S. purposes, not subject to PFIC
However U.S. person likely has U.S. trust reporting (subject to penalties)
If corporation for U.S. purposes, generally subject to PFIC
determinations
Limited purpose trust, open ended, unincorporated, created for investment
purposes
Management of trust has powers to “vary the investments”
Certain Canadian corporations
Junior investment stock likely PFICs
IPOs
Certain REITs
Likely not subject to PFIC if active property management by REIT
itself
Most CEFs
Includes privately owned companies!
Information circulars (and other fund documents) are starting to
5. PFIC
Sample PFIC Calc – Non-QEF or Mark-To
Market
U.S. Citizen Buys Canadian Junior Mining Stock in 2007 for
$ 1,000 US
Sells all of the stock in 2010 for $ 10,000 US
The $ 9,000 US gain will be taxed at an effective rate of
37% in the United States*
The longer the hold of the stock, the higher the effective
rate
Annual distributions can create “excess distributions” as
well
*(assuming the underpayment interest rate in 2010 is the same as 2009)
6. FBAR redux
Additional Disclosure Required: new form
“Specified Foreign Financial Asset” disclosure
Includes:
Deposits (or custodial accounts) at foreign financial institutions
To the extent not held at a financial institution:
Stocks or securities issued by foreign persons
Any other financial instrument or contract held for investment that is issued
or has a counterparty that is not a U.S. person
Any interest in a foreign entity.
Aggregate value of the assets must exceed $ 50,000 US
If you can’t prove aggregate value, IRS will assume you met the
threshold
Congress does not believe this to be a duplicative reporting to
FBAR (which is still in effect)
Failure to disclose is $ 10,000 US for every tax year
Statute of limitations is suspended INDEFINITELY if never filed
7. US tax rate changes
Changes to U.S. Individual FTCs -As of 2009
Foreign Dividends in excess of $ 20,000 US are subject to FTC
stripping
Changes to U.S. Individual Tax Rates -As of 2011
Top marginal rate goes to 39.6%
Long-term capital gains rate to 20%
Qualified dividends ordinary rates - no longer 15%
Foreign tax credits – un-pooling, again
Impact for planning:
• foreign exchange rate implications
• Dividend tax credit issues
8. US tax rate changes
Personal Income tax rates:
MFS:
Over $70,000 but not over $125,000. $17,964.25, plus 36% of the
excess over $70,000.
Over $125,000....... $37,764.25, plus 39.6% of the excess over
$125,000.
MFJ:
Over $140,000 but not over $250,000. $35,928.50, plus 36% of the
excess over $140,000.
Over $250,000....... $75,528.50, plus 39.6% of the excess over
$250,000.
9. US tax rate changes
US Healthcare bill: requires US persons to have
healthcare coverage that meets US standard. Penalties for
insufficient coverage – no exemption for U.S. persons living outside
US.
Q:How does this impact US Persons living
in Canada? Private insurance required?
2012: 3.8% healthcare surtax on investment
income where AGI over $250,000 MFJ
Planning: analysis for high net-worth
individuals
11. US tax rate changes
Estate taxes Exemption $1M – 3.5M?
• Retro-active?
• The estate tax exemption will drop to $1 million.
• The GST exemption will drop to an inflation-adjusted $1
million (it is likely this amount will be at least
$1,340,000).
• The top estate, gift, and GST tax rate will increase to
55% (60% for estate and gift tax transfers between
$10 million and $17,184,000).
• The estate and gift tax system will again be unified.
• The state death tax credit will be restored.
12. Vol Dec update
Voluntary Disclosure Update
• Mitigation of Penalties
Up to Audit Manager assigned to file
If “offer” rejected, proceed to audit
• Additional Requests
Account statements for 2003 through 2008
Not all agents request this
Some won’t discuss mitigation unless we
provide this first
Copies of Canadian tax returns filed
Includes corporate returns of CFCs
13. Vol Dec update
Non-Compliance Going Forward
• No “quiet disclosure”
IRS is setting up programs to trigger inspections of
multiple/previous year’s filings
Is considered a willful failure to file and will be subject to no relief of
penalties
• All non-compliance must be sent to Voluntary
Disclosure department
No guidance on what the procedures and likeliness of
penalty mitigation at this time
14. CFC refresher IRC 951-957
What is a Controlled Foreign Corp?
• 5 or fewer US persons with at least 10%
interest (combined filing allowed)
• Attribution rules (family, psps, trusts,corps IRC
318)
• Subpart F income = FAPI – dividend at
ordinary rates (results in double taxation)
• Failure to file penalty: $10,000 per corp
• Complex form – requires USD and US gaap
Recent case: CCA 200645023 – complexity not
reasonable cause
15. CFC – IRC 954
IRC 954 Subpart F Income
What comprises PHC income?
1. Dividends, interest, rents, royalties, and annuities;
2. Income equivalent to interest (without regard to the
exceptions for amounts apportioned like interest);
3. Foreign currency gains or loss (without regard to the
exception for gain or loss directly related to business
needs);
4. Gain or loss from commodities transactions (without
regard to the exclusions for qualified active sales and
qualified hedging transactions); and
5. Gain or loss from certain property transactions
(without regard to the exceptions for sales of
inventory and dealer property).
16. CFC – IRC 954
Limitation:
• The subpart F income of a controlled
foreign corporation for a taxable year
cannot exceed the earnings and profits of
the corporation for that year
• Claw-back rule for subsequent profits
17. CFC – IRC 954
IRC 954 fix for CFCs with Subpart F income:
ULC
Pros & Cons:
• Income retains character in hands of US
person (capital gains, dividends)
• Requires maintenance of portfolio in CAD
and USD
• issue with US investments? Treaty? Code?
18. Miscellaneous legislative changes
Codification of economic substance:
IRC 7701(o)
Substantial penalties for transactions lacking economic
substance (20% - 40%)
economic substance is a conjunctive test—that is, a
transaction (or series of transactions) to which the
economic substance doctrine applies is treated as
having economic substance only if (1) it changes in a
meaningful way (apart from any U.S. federal income
tax effects) the taxpayer's economic position; and (2)
the taxpayer has a substantial purpose (apart from
U.S. federal income tax effects) for entering into the
transaction
19. Miscellaneous
Purpose of legislation:
• sham transactions - sole purpose of obtaining tax
benefits and the transaction is devoid of any reasonable opportunity
for economic profit
• sales leasebacks
Result: potentially wide-ranging – could
impact typical reorganization planning
eg. Sale of US stocks to spouse
20. Miscellaneous
Adequate Disclosure (Rev Proc 2010-15)
a.k.a. why the cost of compliance just went up
Applies to all tax filers and preparers
Substantial understatement of tax: IRC 6662(1)
Individuals: understatement exceeds greater of
10% or $5,000
Corporations: understatement exceeds lesser of
10% or (or if greater $10,000) $10M
21. Miscellaneous
Inadequate disclosure includes:
• Unclear descriptives
• Compensation of officers (Sch E)
• Repairs
• Combining unlike items
• Schedule A Itemized deduction details
• Trade or business
Consider Form 8275 or 8275-R disclosure?
22. Miscellaneous
Restructuring at IRS
• High net worth individuals (>$10M) now
part of “corp” audit group
Washington B&O tax
• Sweeping changes to nexus rules – any
activity directed at WA
residents/businesses
• If activity stopped “trailing nexus” for
current + next year
23. Miscellaneous
Canadian trust – vacation property
US person or non-compliant snowbird meeting substantial
presence who is grantor or beneficiary of trust occupies
US ppty – fair market value of use of
residence as distribution (taxable amt
limited to net income but may have
deemed rental income)
24. Canadian tax potpourri
Foreign tax credit generators
Proposed amendments: restrict entitlement
to deductions & credits for foreign taxes in
respect of foreign-source income
Target: hybrid instrument structures
Unintended result? – partnership structures
Denial of % of FTCs if income under other
country rules is less than Cdn equivalent
25. Canadian tax potpourri
Taxable Canadian property
Non-public company shares excluded unless
anytime in last 60 months more than 50% of
FMV (direct or indirect) combo of:
1) Real or immovable property
2) Resource
3) Timber
4) Options or interests in above
Similar rules apply to NR corps, psp interests,
mutual fund trusts
Exchange taint under section 85
• Shares received by transferor deemed TCP for
60 months following transfer
26. Canadian tax potpourri
Tax avoidance transactions:
Following US and QC models?
Meets two of three “hallmark” tests:
1. Promoter/tax advisor fees (a) attributable to
benefit; (b) contingent on tax benefit; or (c) # of
participants;
2. Promoter requires “confidential protection”;
3. Taxpayer receives “contractual protection”;
Result: any tax benefit sought not available until
reported and, if applicable, penalty for failure is
paid.
27. Canadian tax potpourri
Employee stock options:
• Elimination of deferral for pubco stock options
Result: better matching of Cdn & US tax
consequences
• Remittance obligations – amounts must be
remitted for stock option benefit as if cash
payment (with reduction for 50%)
Applies: 2011 exercises
Exemption: a) stock options granted prior to
2011; b) entered to prior to March 4, 2010; and
c) restrictions on disposition.
28. Canadian tax potpourri
TD Securities (USA) LLC v. Queen 2008-
2314(IT)G, April 8, 2010
Held: US LLC was resident entitled to treaty
benefits under former convention
Fact pattern: Two tier US C corporation blocker
with LLC