This document provides an overview and summary of Canada-U.S. cross-border tax issues presented by Alpesh Joshi, CA, CPA. It discusses the services provided by AJPCA related to cross-border tax compliance, international tax, and consulting. It highlights some key impacts of the new fifth protocol to the Canada-U.S. Tax Treaty, including changes to the definition of permanent establishment and treatment of hybrid entities. It also covers issues like foreign bank reporting requirements, obtaining an ITIN number, and nexus for U.S. income and sales tax purposes. The presentation aims to make bankers aware of common cross-border tax concerns faced by individuals and corporations.
Webinar: Sales Tax Issues to Keep an Eye Out For!Withum
This document discusses sales tax issues and provides an overview of nexus rules and the impact of the Wayfair decision. It summarizes key sales tax concepts such as nexus, economic nexus, marketplace facilitators, and taxability of software. The document advises reviewing a company's existing and post-Wayfair nexus footprint, assessing taxability of products/services, considering technology needs, and preparing to register and comply with new state sales tax requirements.
The document discusses whether P.L. 86-272, a 1959 law that protects businesses from state income taxes if they only solicit sales in a state, is unconstitutional or discriminatory. It notes that the law does not apply to companies that sell services or intangibles. This means those companies can face state income tax liability even if their in-state activities are limited to solicitation. However, companies that sell tangible goods are protected from taxation under similar circumstances. The author argues this unequal treatment may violate the equal protection clause of the 14th Amendment and questions whether updating or changing P.L. 86-272 is overdue to address this potential unconstitutionality.
Seminar Best Year To Buy Sell (Ver2 Final)tjmeyer1234
The document discusses why 2012 may be the best year to buy or sell a business due to pending changes and uncertainties. It notes that current tax incentives are set to expire at the end of 2012, which would significantly increase taxes on income, capital gains, and estates. Increased regulation, litigation risks, national debt, healthcare costs, and economic uncertainty also contribute to a challenging business environment. Selling a business in 2012 allows owners to take advantage of more favorable tax rates and estate tax exemptions before their anticipated rise in 2013.
An IC-DISC is a domestic corporation that allows US companies to defer taxes on a portion of export income. To qualify as an IC-DISC, a corporation must be domestic, have minimum capital, elect IC-DISC status, and have qualified export property. An IC-DISC is not taxed, but pays tax-deferred commissions to shareholders. This can permanently reduce the tax rate on export income by up to 15.8%. IC-DISCs are commonly set up as passive entities receiving commissions from a related supplier in exchange for qualifying export sales.
The MTC’s Restatement on PL 86-272 Expands State’s Ability to Impose Income T...Withum
P.L. 86-272 says that a state cannot impose an income tax if a company's only connection to that state is soliciting sales of tangible personal property. Historically, certain activities have been protected under P.L. 86-272, such as soliciting orders, providing samples, and maintaining property for salespeople. However, other activities can cause a company to lose P.L. 86-272 protection, like fulfilling orders, performing repairs, owning inventory in the state, or having employees perform non-sales activities. As the economy has evolved, it has become more difficult for companies to limit their activities to just solicitation and remain under P.L. 86-272's protections.
The document provides a financial planning primer for US taxpayers living abroad. It highlights reporting and compliance requirements for US taxpayers under current legislation. It also outlines strategies for saving in a tax efficient manner for retirement. Key points include understanding FATCA global reporting rules, reporting annual income and worldwide assets, and exploring tax treaties and structures like International Pension Plans to maximize tax efficiency and flexibility. Overall the document aims to help US taxpayers living abroad understand their obligations while pursuing wealth accumulation and retirement planning goals.
Doing business in the united states presentation 101028 (1)Denis Dovgopoliy
The document provides an overview of key considerations for doing business in the United States, including:
1) Regulatory environment covers areas like antitrust, consumer protection, intellectual property, accounting standards.
2) Choice of entity includes LLC, LP, C Corp, S Corp which provide liability protection.
3) Transfer pricing is important for related party transactions to reflect arm's length prices and avoid penalties.
Webinar: Sales Tax Issues to Keep an Eye Out For!Withum
This document discusses sales tax issues and provides an overview of nexus rules and the impact of the Wayfair decision. It summarizes key sales tax concepts such as nexus, economic nexus, marketplace facilitators, and taxability of software. The document advises reviewing a company's existing and post-Wayfair nexus footprint, assessing taxability of products/services, considering technology needs, and preparing to register and comply with new state sales tax requirements.
The document discusses whether P.L. 86-272, a 1959 law that protects businesses from state income taxes if they only solicit sales in a state, is unconstitutional or discriminatory. It notes that the law does not apply to companies that sell services or intangibles. This means those companies can face state income tax liability even if their in-state activities are limited to solicitation. However, companies that sell tangible goods are protected from taxation under similar circumstances. The author argues this unequal treatment may violate the equal protection clause of the 14th Amendment and questions whether updating or changing P.L. 86-272 is overdue to address this potential unconstitutionality.
Seminar Best Year To Buy Sell (Ver2 Final)tjmeyer1234
The document discusses why 2012 may be the best year to buy or sell a business due to pending changes and uncertainties. It notes that current tax incentives are set to expire at the end of 2012, which would significantly increase taxes on income, capital gains, and estates. Increased regulation, litigation risks, national debt, healthcare costs, and economic uncertainty also contribute to a challenging business environment. Selling a business in 2012 allows owners to take advantage of more favorable tax rates and estate tax exemptions before their anticipated rise in 2013.
An IC-DISC is a domestic corporation that allows US companies to defer taxes on a portion of export income. To qualify as an IC-DISC, a corporation must be domestic, have minimum capital, elect IC-DISC status, and have qualified export property. An IC-DISC is not taxed, but pays tax-deferred commissions to shareholders. This can permanently reduce the tax rate on export income by up to 15.8%. IC-DISCs are commonly set up as passive entities receiving commissions from a related supplier in exchange for qualifying export sales.
The MTC’s Restatement on PL 86-272 Expands State’s Ability to Impose Income T...Withum
P.L. 86-272 says that a state cannot impose an income tax if a company's only connection to that state is soliciting sales of tangible personal property. Historically, certain activities have been protected under P.L. 86-272, such as soliciting orders, providing samples, and maintaining property for salespeople. However, other activities can cause a company to lose P.L. 86-272 protection, like fulfilling orders, performing repairs, owning inventory in the state, or having employees perform non-sales activities. As the economy has evolved, it has become more difficult for companies to limit their activities to just solicitation and remain under P.L. 86-272's protections.
The document provides a financial planning primer for US taxpayers living abroad. It highlights reporting and compliance requirements for US taxpayers under current legislation. It also outlines strategies for saving in a tax efficient manner for retirement. Key points include understanding FATCA global reporting rules, reporting annual income and worldwide assets, and exploring tax treaties and structures like International Pension Plans to maximize tax efficiency and flexibility. Overall the document aims to help US taxpayers living abroad understand their obligations while pursuing wealth accumulation and retirement planning goals.
Doing business in the united states presentation 101028 (1)Denis Dovgopoliy
The document provides an overview of key considerations for doing business in the United States, including:
1) Regulatory environment covers areas like antitrust, consumer protection, intellectual property, accounting standards.
2) Choice of entity includes LLC, LP, C Corp, S Corp which provide liability protection.
3) Transfer pricing is important for related party transactions to reflect arm's length prices and avoid penalties.
2021 Year End Tax Planning for Law Firms and AttorneysWithum
This document provides an overview and summary of a webinar on 2021 year-end tax planning for law firms and attorneys. It discusses various federal tax law updates and proposals, as well as strategies for year-end tax planning including deferring income, accelerating expenses, maximizing deductions, and utilizing available exemptions and exclusions for estate and gift tax purposes before potential changes in 2022. The webinar covers individual, business, retirement, and pass-through entity tax considerations and implications.
The document discusses Nevada's struggle to fund its government as its reliance on tourism and gambling revenues is no longer sufficient. It introduced the Nevada Commerce Tax enacted in 2015 to address budget shortfalls, which is similar to a margin tax proposal voters rejected in 2014. The tax faces legal challenges for ignoring the will of the voters. The Modified Business Tax implemented in 2003 also does not fully solve Nevada's fiscal problems on its own.
Investment Tax Landscape Countdown To 2013dvanderjagt
The document discusses the tax landscape between now and 2013 as Congress wrestles with budget deficit issues. It may represent a stay of execution for higher taxes rather than a pardon. Several types of investors should pay attention to planning, including those with substantial capital gains, those reliant on dividends/bonds for income, and those investing in small businesses. Capital gains and dividend tax rates may increase after 2012, and tax-free municipal bonds may become relatively more attractive for high-income investors. The 100% capital gains exclusion was extended for qualifying small business stock issued before January 2012.
[ON-DEMAND WEBINAR] Revealing The State & Local Tax Considerations Of A Remot...Rea & Associates
Tax Consequences Holding You Back From Deploying A Remote Workforce?
As remote work continues to overtake the traditional workforce, organizations must understand state and local tax considerations for their remote employees before adopting such a policy. Due to quick changes in the work environment and work-from-home arrangements many tax consequences that may result in your business reconsidering the deployment of a remote workforce. Fortunately, state and local tax leader and a principal with Rea & Associates, Kathy LaMonica, will be on hand to explain what businesses are up against. She will also be taking your questions throughout the presentation. Read on to discover what you will hear during this free, hour-long webinar.
State & Local Tax Guidance To Guide Your Remote Workforce Decision
Join Rea & Associates for a free, hour-long webinar to gain insight on tax law updates, remote work implications, what land mines you need to be aware of when registering for payroll taxes in new states, and more. During this event, you will:
- Gain insight on the Wayfair decision, and recent updates that may affect your business 3 years later.
- Take a deep dive into the State and Local direct and indirect tax concerns when hiring remote workers.
- Receive an update on Ohio Municipal Tax legal challenges.
- Tune in for predictions of where the states may be headed with the taxability of services and digital products, and how that may affect your compliance requirements.
- And more!
Kathy, an income principal on the firm's state and local tax team, focuses on sales and use tax consulting, compliance, and implementing technology solutions for businesses and organizations that continue to struggle with the various tax laws found throughout the nation. Since COVID-19 emerged and the topic of working remote took center stage, she has been tracking the implications associated with deploying a remote workforce. You won't want to miss this one!
#ReaCPA #State&LocalTax #RemoteEmployees
What does the new Tax Cuts and Jobs Act mean for you? Our January Investment Insights explores the key points of the most significant overhaul of the tax system since '86, reviewing the new tax brackets, deductions and exemptions, and the effects on the economy.
Distressed startups legal, business, and financing strategiesRoger Royse
This document provides an overview of legal, business, and financing strategies for distressed startups. It discusses planning for economic downturns, including prioritizing protecting employees and customers, financial modeling, defending revenue, stabilizing operations, reducing costs, and pursuing opportunities. The document also covers terms investors may seek in troubled financings like resetting the cap table, pay-to-play provisions, and anti-dilution protections. M&A activity, government assistance programs, and defenses for non-performance like force majeure are additionally summarized.
1) The document discusses double taxation avoidance agreements (DTAAs) between India and other countries.
2) DTAAs aim to avoid double taxation that may occur when the same income is taxed in both the country of residence and the country of source.
3) India has 84 DTAAs currently with other countries based on either the OECD or UN model conventions. The DTAAs provide relief from double taxation and clarify taxing rights between the two countries.
Thanks to Ulster Savings Bank for hosting this event, guest speaker Jonathan Gudema of Planned Giving Advisors and to all of our participants for joining us to learn more about the impact of the new tax law on charitable giving.
This document discusses a joint venture partnership program called Partners in Research. It describes how the program works, the benefits it provides, and the potential tax savings. Specifically:
- A participant takes out a 7-year loan through Partners in Research, which uses the funds to support various research companies. Losses from the research are allocated to the participant to reduce their taxable income.
- For a $375,000 loan, annual costs of $16,875 could generate $45,000 in losses, reducing taxable income by $61,875 and saving over $25,000 in taxes.
- Partners in Research guarantees repayment of the loan and covers taxes in the event of a reassessment. The
Professionals in the tax community are tasked with developing planning strategies under existing statutory schemes that minimize or eliminate their clients’ global tax burden. It is these planning structures that draw the attention of tax authorities as causing the “erosion” of taxable income bases and consequently, the tax revenues for their respective countries.
PPP Loan Intricacies and Tax Considerations for Subcontractors Withum
This document discusses tax provisions and small business loans provided by the CARES Act in response to COVID-19. It outlines the extension of tax filing and payment deadlines to July 15, 2020, employee retention credits of up to $5,000 per employee, options to defer payroll tax payments, changes to net operating loss carrybacks and interest deductions, and the Paycheck Protection Program for small business loans that may be forgiven.
The American Taxpayer Relief Act of 2012:
1) Allowed Bush-era tax rates to expire for individuals earning over $400,000 and families over $450,000, raising their tax rate to 39.6%;
2) Permanently patched the AMT by increasing exemption amounts; and
3) Provided for a maximum 40% estate tax and $5 million exemption.
It effectively raised taxes for all by not extending a payroll tax cut and delayed mandatory spending cuts. Congress will revisit tax and spending policies when addressing the debt limit in February, with entitlement reforms and the "chained CPI" likely to be controversial topics.
This document summarizes potential impacts of the Trump administration on Mexico, including promised protectionist measures like renegotiating or withdrawing from NAFTA. It also discusses options for dismantling NAFTA without congressional approval, Mexico's network of international agreements, recent Mexican anti-corruption reforms, and potential restructuring needs for companies with shelter operations in Mexico in 2018.
The document discusses succession planning for family businesses and navigating taxes. It begins by noting that any transfer of assets between individuals or entities carries potential tax implications like income, gift, estate, or excise taxes. The key is to identify the client's objectives upfront, understand their history and fears, and tailor a plan to minimize taxable transfers and maximize tax exclusions and credits. This allows transferring value below taxation thresholds while still maintaining some control. Tools like trusts, annual gift exclusions, and flow-through entities can help transfer assets out of the estate while addressing client concerns about maintaining control and access to income. The overall goal is a comprehensive plan that moves assets to the desired destination with the fewest tax obstacles.
With the passage and implementation of the Tax Cuts and Jobs Act (TCJA), comes a lot of changes for taxpayers to wrap their heads around – but we’re up to the challenge.
Even with all the information floating around these days, it’s easy to overlook or misinterpret how the law works. Don’t worry; with this presentation, we'll provide you the important tips and insights surrounding this law.
The Canadian government released its first budget under Prime Minister Paul Martin which includes significant future spending commitments. However, some members of Canada's business community are worried that the budget does not do enough to maintain the country's competitiveness in the global economy through tax incentives and other measures. While the budget was received positively by some groups, others such as the Canadian Manufacturers & Exporters Association believe the government's competitiveness agenda is not being implemented quickly enough. There is debate around whether the tax reductions and other measures in the budget will be sufficient to attract investment and keep Canada competitive internationally over the long term.
Telecommunication, radio, television, computers, and the internet have all evolved significantly over time. Telecommunication evolved from the telegraph to include the telephone, fiber optics, satellites, and the internet. Radio evolved from AM/FM to include satellite radio and internet radio. Television evolved from cable to direct-to-home satellite and internet TV. Computers transformed from first generation mainframes to include graphical user interfaces and the internet which began as ARPANET and allowed for downloading and streaming media.
Programming involves using computer languages to develop applications, scripts, or other instructions for computers. It is a creative process where programmers instruct computers on tasks through programming languages. There are many programming languages available, with some of the most common being C++ and Dev C++. Programming can involve various structures like switch statements and loops to control program flow and repetition.
The document discusses banking developments and perspectives in India from 1999-2000. It covers several key policy initiatives over this period including reducing interest rates and cash reserve requirements in 1999-2000 to stimulate the economy, then increasing them again in 2000-2001. It also discusses structural reform measures aimed at increasing monetary policy effectiveness, strengthening prudential norms, improving credit delivery, and developing financial sector infrastructure. Several money market reforms are outlined that aimed to liberalize the money market and develop segments like commercial paper.
2021 Year End Tax Planning for Law Firms and AttorneysWithum
This document provides an overview and summary of a webinar on 2021 year-end tax planning for law firms and attorneys. It discusses various federal tax law updates and proposals, as well as strategies for year-end tax planning including deferring income, accelerating expenses, maximizing deductions, and utilizing available exemptions and exclusions for estate and gift tax purposes before potential changes in 2022. The webinar covers individual, business, retirement, and pass-through entity tax considerations and implications.
The document discusses Nevada's struggle to fund its government as its reliance on tourism and gambling revenues is no longer sufficient. It introduced the Nevada Commerce Tax enacted in 2015 to address budget shortfalls, which is similar to a margin tax proposal voters rejected in 2014. The tax faces legal challenges for ignoring the will of the voters. The Modified Business Tax implemented in 2003 also does not fully solve Nevada's fiscal problems on its own.
Investment Tax Landscape Countdown To 2013dvanderjagt
The document discusses the tax landscape between now and 2013 as Congress wrestles with budget deficit issues. It may represent a stay of execution for higher taxes rather than a pardon. Several types of investors should pay attention to planning, including those with substantial capital gains, those reliant on dividends/bonds for income, and those investing in small businesses. Capital gains and dividend tax rates may increase after 2012, and tax-free municipal bonds may become relatively more attractive for high-income investors. The 100% capital gains exclusion was extended for qualifying small business stock issued before January 2012.
[ON-DEMAND WEBINAR] Revealing The State & Local Tax Considerations Of A Remot...Rea & Associates
Tax Consequences Holding You Back From Deploying A Remote Workforce?
As remote work continues to overtake the traditional workforce, organizations must understand state and local tax considerations for their remote employees before adopting such a policy. Due to quick changes in the work environment and work-from-home arrangements many tax consequences that may result in your business reconsidering the deployment of a remote workforce. Fortunately, state and local tax leader and a principal with Rea & Associates, Kathy LaMonica, will be on hand to explain what businesses are up against. She will also be taking your questions throughout the presentation. Read on to discover what you will hear during this free, hour-long webinar.
State & Local Tax Guidance To Guide Your Remote Workforce Decision
Join Rea & Associates for a free, hour-long webinar to gain insight on tax law updates, remote work implications, what land mines you need to be aware of when registering for payroll taxes in new states, and more. During this event, you will:
- Gain insight on the Wayfair decision, and recent updates that may affect your business 3 years later.
- Take a deep dive into the State and Local direct and indirect tax concerns when hiring remote workers.
- Receive an update on Ohio Municipal Tax legal challenges.
- Tune in for predictions of where the states may be headed with the taxability of services and digital products, and how that may affect your compliance requirements.
- And more!
Kathy, an income principal on the firm's state and local tax team, focuses on sales and use tax consulting, compliance, and implementing technology solutions for businesses and organizations that continue to struggle with the various tax laws found throughout the nation. Since COVID-19 emerged and the topic of working remote took center stage, she has been tracking the implications associated with deploying a remote workforce. You won't want to miss this one!
#ReaCPA #State&LocalTax #RemoteEmployees
What does the new Tax Cuts and Jobs Act mean for you? Our January Investment Insights explores the key points of the most significant overhaul of the tax system since '86, reviewing the new tax brackets, deductions and exemptions, and the effects on the economy.
Distressed startups legal, business, and financing strategiesRoger Royse
This document provides an overview of legal, business, and financing strategies for distressed startups. It discusses planning for economic downturns, including prioritizing protecting employees and customers, financial modeling, defending revenue, stabilizing operations, reducing costs, and pursuing opportunities. The document also covers terms investors may seek in troubled financings like resetting the cap table, pay-to-play provisions, and anti-dilution protections. M&A activity, government assistance programs, and defenses for non-performance like force majeure are additionally summarized.
1) The document discusses double taxation avoidance agreements (DTAAs) between India and other countries.
2) DTAAs aim to avoid double taxation that may occur when the same income is taxed in both the country of residence and the country of source.
3) India has 84 DTAAs currently with other countries based on either the OECD or UN model conventions. The DTAAs provide relief from double taxation and clarify taxing rights between the two countries.
Thanks to Ulster Savings Bank for hosting this event, guest speaker Jonathan Gudema of Planned Giving Advisors and to all of our participants for joining us to learn more about the impact of the new tax law on charitable giving.
This document discusses a joint venture partnership program called Partners in Research. It describes how the program works, the benefits it provides, and the potential tax savings. Specifically:
- A participant takes out a 7-year loan through Partners in Research, which uses the funds to support various research companies. Losses from the research are allocated to the participant to reduce their taxable income.
- For a $375,000 loan, annual costs of $16,875 could generate $45,000 in losses, reducing taxable income by $61,875 and saving over $25,000 in taxes.
- Partners in Research guarantees repayment of the loan and covers taxes in the event of a reassessment. The
Professionals in the tax community are tasked with developing planning strategies under existing statutory schemes that minimize or eliminate their clients’ global tax burden. It is these planning structures that draw the attention of tax authorities as causing the “erosion” of taxable income bases and consequently, the tax revenues for their respective countries.
PPP Loan Intricacies and Tax Considerations for Subcontractors Withum
This document discusses tax provisions and small business loans provided by the CARES Act in response to COVID-19. It outlines the extension of tax filing and payment deadlines to July 15, 2020, employee retention credits of up to $5,000 per employee, options to defer payroll tax payments, changes to net operating loss carrybacks and interest deductions, and the Paycheck Protection Program for small business loans that may be forgiven.
The American Taxpayer Relief Act of 2012:
1) Allowed Bush-era tax rates to expire for individuals earning over $400,000 and families over $450,000, raising their tax rate to 39.6%;
2) Permanently patched the AMT by increasing exemption amounts; and
3) Provided for a maximum 40% estate tax and $5 million exemption.
It effectively raised taxes for all by not extending a payroll tax cut and delayed mandatory spending cuts. Congress will revisit tax and spending policies when addressing the debt limit in February, with entitlement reforms and the "chained CPI" likely to be controversial topics.
This document summarizes potential impacts of the Trump administration on Mexico, including promised protectionist measures like renegotiating or withdrawing from NAFTA. It also discusses options for dismantling NAFTA without congressional approval, Mexico's network of international agreements, recent Mexican anti-corruption reforms, and potential restructuring needs for companies with shelter operations in Mexico in 2018.
The document discusses succession planning for family businesses and navigating taxes. It begins by noting that any transfer of assets between individuals or entities carries potential tax implications like income, gift, estate, or excise taxes. The key is to identify the client's objectives upfront, understand their history and fears, and tailor a plan to minimize taxable transfers and maximize tax exclusions and credits. This allows transferring value below taxation thresholds while still maintaining some control. Tools like trusts, annual gift exclusions, and flow-through entities can help transfer assets out of the estate while addressing client concerns about maintaining control and access to income. The overall goal is a comprehensive plan that moves assets to the desired destination with the fewest tax obstacles.
With the passage and implementation of the Tax Cuts and Jobs Act (TCJA), comes a lot of changes for taxpayers to wrap their heads around – but we’re up to the challenge.
Even with all the information floating around these days, it’s easy to overlook or misinterpret how the law works. Don’t worry; with this presentation, we'll provide you the important tips and insights surrounding this law.
The Canadian government released its first budget under Prime Minister Paul Martin which includes significant future spending commitments. However, some members of Canada's business community are worried that the budget does not do enough to maintain the country's competitiveness in the global economy through tax incentives and other measures. While the budget was received positively by some groups, others such as the Canadian Manufacturers & Exporters Association believe the government's competitiveness agenda is not being implemented quickly enough. There is debate around whether the tax reductions and other measures in the budget will be sufficient to attract investment and keep Canada competitive internationally over the long term.
Telecommunication, radio, television, computers, and the internet have all evolved significantly over time. Telecommunication evolved from the telegraph to include the telephone, fiber optics, satellites, and the internet. Radio evolved from AM/FM to include satellite radio and internet radio. Television evolved from cable to direct-to-home satellite and internet TV. Computers transformed from first generation mainframes to include graphical user interfaces and the internet which began as ARPANET and allowed for downloading and streaming media.
Programming involves using computer languages to develop applications, scripts, or other instructions for computers. It is a creative process where programmers instruct computers on tasks through programming languages. There are many programming languages available, with some of the most common being C++ and Dev C++. Programming can involve various structures like switch statements and loops to control program flow and repetition.
The document discusses banking developments and perspectives in India from 1999-2000. It covers several key policy initiatives over this period including reducing interest rates and cash reserve requirements in 1999-2000 to stimulate the economy, then increasing them again in 2000-2001. It also discusses structural reform measures aimed at increasing monetary policy effectiveness, strengthening prudential norms, improving credit delivery, and developing financial sector infrastructure. Several money market reforms are outlined that aimed to liberalize the money market and develop segments like commercial paper.
Wheat straw represents a promising source of lignocellulosic biomass for second generation bioethanol production. Global wheat production results in over 850 teragrams of wheat straw annually, which could potentially produce 120 gigaliters of ethanol to replace 93 gigaliters of gasoline. However, pretreatment, enzymatic hydrolysis, fermentation and distillation are required to convert the cellulose, hemicellulose and lignin in wheat straw into ethanol. Ongoing research aims to reduce the costs of pretreatment and enzymes in order to make lignocellulosic ethanol competitive with gasoline.
Dokumen tersebut membahas tentang teori orbital atom dan hukum periodik unsur kimia. Teori orbital atom dikemukakan oleh Erwin Schrodinger pada tahun 1926 untuk menjelaskan letak elektron dalam atom, sedangkan hukum periodik dikembangkan oleh berbagai ilmuwan untuk mengatur susunan unsur kimia berdasarkan sifat periodiknya.
This document summarizes taxation considerations for Canadian corporations doing business in the United States. It discusses operating through a U.S. branch or subsidiary. A U.S. branch faces U.S. income tax, but treaty protection may apply if no permanent establishment exists. Creating a permanent establishment can occur through physical presence or employee activities. Operating through a U.S. subsidiary also faces U.S. income tax. State taxation depends on whether sufficient nexus exists in a state based on contacts like visits, equipment, or offices. Public Law 86-272 provides some protection for limited state presences. The document provides contacts for further tax questions.
Doing business in an international context can be daunting. WeiserMazars serves as a bridge between the United States and the global markets, making doing business easier and less risky for our clients. We connect overseas clients with American professionals and service the tax, transaction services and financial reporting needs of foreign entities based in the U.S.
What Is Life After Coronavirus? State and Local Tax: First Wave Response & Se...Rea & Associates
This free, high-level coronavirus overview is designed to help employers make sense of the state and local tax decisions to consider as the COVID-19 (coronavirus) crisis continues to unfold. Presented by Joe Popp, JD, LLM, a principal with Rea & Associates and the firm's director of state and local tax services, the hour-long presentation will cover the first wave of state and local tax department responses and will then move on to guidance for businesses and individuals who are preparing for the second wave of crisis response.
Specifically, this webinar will cover:
- Insight about the first wave of state and local tax responses and how tax departments are answering individuals and businesses during the COVID-19 crisis.
- Guidance on how to prepare for the next wave of decisions made by your state and local tax departments.
- Predictions on what states will do in the future as a result of the COVID-19 crisis.
Discover more information about the California Competes Credit application a tax credit incentives program recently created by the state of California. Companies looking to apply need to do so before April 14, 2014 - O'Connor Davies CPAs - New York CPA Firm
Taxes Without Borders- The Essential Guide for U.S. Residents Living AbroadUSA Expat Taxes
As a U.S. resident living and working abroad, understanding your tax obligations can be a daunting task. Unlike many other countries, the United States imposes a global taxation system, which means that even if you're earning income overseas, you're still required to file and pay taxes to the IRS. However, fear not! This comprehensive guide will equip you with the essential knowledge to navigate the complexities of American tax for U.S. residents living abroad.
The IRS is making several changes to their tax lien process to help struggling taxpayers, including increasing the dollar threshold for when liens are issued which should result in fewer liens. They are also expanding installment agreement programs for small businesses and the streamlined offer in compromise program. Critics say the changes do not go far enough, while others see it as a step in the right direction to provide more flexibility for taxpayers getting back on track with their tax obligations.
The document discusses issues around corporate tax reform and inversions in the US. It notes that while politicians call for action, comprehensive tax reform is unlikely before or just after the 2016 election. Temporary measures may not stop companies moving to lower tax countries. The IRS is seeking more data to enforce current laws and prepare for potential future reforms from studies on base erosion and profit shifting. Multinational companies should prepare to react to potential upcoming changes to tax laws.
This document provides information about a seminar on U.S. taxation issues for expatriates presented by AmCham Bahrain. The guest speaker, Stuart Horwich, is a U.S. attorney who has extensive experience advising international clients on U.S. tax issues. The seminar covered topics such as U.S. citizens' tax liability regardless of residence, income tax rates and brackets, exclusions for earned and housing income abroad, reporting of foreign bank accounts, and options for non-filers to become compliant.
Cleaning Up Your Tax with Voluntary Disclosure AgreementsCBIZ, Inc.
While paying taxes might not be our favorite pastime, the overwhelming majority of taxpayers strive to file and pay all of their tax obligations. However, sometimes taxpayers' best efforts to comply with their tax obligations are not enough, especially in the state and local tax world. Although it may be an innocent mistake, such non-compliance may be very costly if it is first discovered by the state or local taxing jurisdiction, because the taxpayer will not only be subject to tax and interest but also harsh penalties (up to 25 percent or more).
This document summarizes taxation considerations for Canadian corporations doing business in the United States through no taxable presence, a U.S. branch, or a U.S. subsidiary corporation. It discusses federal taxation, state taxation, and considerations for operating through a branch versus entity. Key points include outlining what creates tax nexus and permanent establishment for Canadian companies, and implications of the U.S.-Canada tax treaty and Public Law 86-272 for state taxation.
This article on your 2016 tax return and tax planning tips for nonqualified deferred compensation plans is reprinted with permission of myNQDC.com, a respected source of information, content, and tools on nonqualified deferred compensation.
Tax Guide to Overseas Real Estate Investments for U.S. InvestorsDurise
Before you even begin to consider a jump into the foreign real estate investment pool, it’s important to become as knowledgeable about the entire process as possible. One item that is particularly important to research and understand is the tax implications that go along with property investing overseas. To that end, we’ve put together this tax guide to help U.S. real estate investors gather some much needed tax information.
Global companies investing in the United States face unique opportunities and challenges. Doing business in the US reviews the key tax issues and provides insights to help investors navigate the US business environment.
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.
Taxpayers are encouraged to heed the advice of the IRS and file undisclosed assets with the government through the Overseas Voluntary Disclosure Program while it is still available.
Only a few organizations are excused from filing an annual tax return with the Internal Revenue
Service. Anyone with an annual worldwide income below a specified threshold or who meets certain
criteria falls into this category. The IRS website can tell you if you need to file a tax return as a US
ex-pat. It's also a good idea to get advice from a tax expert in the United States.
When leaving the nation, you should consider any tax ramifications to your income. Salaries and
property taxes, for example, are related to specific areas. Cash investments, for example, are
movable assets.
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1. Canada – U.S. Cross-Border Tax
Update
PREPARED AND PRESENTED BY:
Alpesh Joshi, CA, CPA (New Jersey)
7676 Woodbine Avenue, Markham, Ontario L3R 2N2 Tel (647) 977-2572 Fax (416) 628-2511
www.alpeshjoshi.ca www.ustaxsolutions.ca
2. Thinking About Tomorrow… Today
OVERVIEW
•What we do? Value Added Service of AJPCA
•Relevancy of Cross Border issues in Banking
Industry.
•Current U.S. and International Tax Issues.
•Business Development and Banking Service.
•Questions?
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WHAT SERVICE WE PROVIDE…
We offer corporate tax services to businesses and individuals opening
cross-border branches, subsidiaries or filling tax returns for expat
employees. We also provide consultation services for companies who
are considering doing business in the U.S. or Canada. These Services
include:
US- Cross Border Tax Compliance;
Canadian Tax Compliance and Planning;
International Tax;
Transfer Pricing;
Consulting and Advisory Services.
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Circular 230 Disclaimer
Any U.S. tax advice contained herein was not intended or written to
be used, and cannot be used, for the purpose of avoiding penalties that
may be imposed under the Internal Revenue Code or applicable state
or local tax law provisions.
These slides are for educational purposes only and are not intended,
and should not be relied upon, as accounting or tax advice.
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WHY RELEVANT TO EVERYONE
Cross Border Concerns, no longer problem of the wealthy or the
multinational companies;
COMMON INDIVIDUAL ISSUES:
The Purchase of U.S. property, for Rental or Recreational Use;
To be non-resident withholding taxes in U.S. source income or
gambling winnings;
To work in U.S. as an employee or contractor;
Snowbirds;
Dual residents and citizens.
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WHY RELEVANT TO EVERYONE
Typical Canadian Corporation Cross Border Issues:
To sell Products and Services into the U.S.;
To have an U.S. branch or subsidiary office;
To own U.S. properties;
To hire U.S. contractors or employees.
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TREATY PROTOCOL
(Guiding Document for Cross Border Taxation)
Canadian- based companies doing business directly in the U.S. must
pay U.S. taxes, based in the U.S. amount of income earned from their
U.S. business.
The Canada-U.S. Tax Treaty makes it possible for Canadian
companies doing business in the U.S. to prevent the double taxation
that might otherwise arise due to their U.S. tax exposure.
Some recent changes to the Tax Treaty, contained in a new 5 th
Protocol, will help Canadian companies conduct cross-border
business; others, however, have the potential to negatively impact this
business.
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The potential impact of three of the Protocol
changes
1. “Permanent establishment” definition now includes
“providing services”
Whether a Canadian resident is liable to tax in the U.S. is no longer
limited to such criteria as having a “fixed place of business”, permanent
establishment in the U.S. now includes providing services in the U.S.
If anyone from a company travels into U.S. for an aggregate of 183
days or more, in any 12-month period, the company is liable to tax in
U.S.
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The potential impact of three of the Protocol
changes
2. “Hybrid entities” may be subject to higher taxes
“Hybrids” are entities that are regarded one way by Canadian tax law
and another way by U. S. tax law.
The new Protocol, a hybrid entity utilized to make an investment in the
U.S. that might previously of lower Tax Treaty rates, may now be
subject to a 30 percent U.S. withholding tax rate.
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The potential impact of three of the Protocol
changes
3. Eliminating withholding taxes on cross-border
interest payments
Under the new Protocol, withholding tax is generally being eliminated
for payments between non- related parties. Guarantee fees generally
will no longer be subject to withholding tax as well.
This new provisions should reduce borrowing costs and have a positive
impact on cross- border investment.
Also, cross-border businesses have more flexibility in choosing and
working with their bankers. * Important for Bankers
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Individual Taxpayer Identification Number
(ITIN)
ITIN is a tax processing number issued by the Internal Revenue
Service. IRS issues ITINs to individuals who are required to have a
U.S. taxpayer identification number but who do not have, and are not
eligible to obtain a Social Security Number (SSN) from the Social
Security Administration (SSA).
ITINs are issued regardless of immigration status because both
resident and non-resident aliens may have a U.S. filing or reporting
requirement under the Internal Revenue Code.
AJPCA is a Certifying Acceptance Agent registered with the IRS to
process W-7 applications for getting an ITIN.
AJPCA also provides services to corporations including U.S. incorporation and obtaining
an Employer Identification Number (EIN) from IRS;
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Questions to ask your clients:
Are you a US Citizen or resident that spends more then 183 days in the
US?
Do you own US property for recreation or business use?
Do you earn any income or incur any expenses against that investment
property.
Does your company sell products or services into the United States?
Do you plan to retire in the United States?
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Foreign Bank and Financial Accounts Reporting
(FBAR)
Would require taxpayers to file FBAR form with the taxpayer’s tax return,
accordingly turning the FBAR into tax return information and making it
easier for the IRS to enforce FBAR filing requirements.
Penalty: Equal to the lesser of $10,000 per reportable transfer or 10% of
the cumulative amount or value of the unreported covered transfers.
Double 20% accuracy- related penalty when an understatement arises
from a transaction involving a foreign account.
The statute of limitations relating to information returns for six years.
Information sharing that IRS has with the CRA and with Canadian Banks
have got many people nervous.
There are Offshore Voluntary Disclosure Initiatives out in the
Market.
AJPCA has been successful at reducing or removing these
penalties.
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Revisions to Foreign Bank Account Report
(Form TDF90-22.1)
Who must file:
U.S. persons with an interest in foreign bank account, brokerage account and
financial accounts (including mutual fund and RRSP) that have aggregate balance
value of these accounts exceeds $10,000 at any time during the calendar year.
When to file:
File by June 30 for the prior calendar year.
How it is file:
Information report;
Consolidation basis;
Not filed with a taxpayer’s income tax return, must file TDF90-22.1
Penalty for not filing the form: $10,000 (could be higher), may result in
potentially civil penalties, criminal penalties or both.
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United States Income And Sales Tax Issues
(NEXUS)
Nexus in general means a connection or contact, different from Permanent
Establishment.
The term nexus is used in tax law to describe a situation in which a
business has a "nexus" or presence in a state and is thus subject to
state income taxes and to sales taxes for activity within that state.
Nexus describes the amount and degree of business activity that must
be present before a state can tax an entity's income. If a taxpayer has
nexus in a particular state, the taxpayer must pay and collect/remit
taxes in that state. As Nexus is required for states to tax, it is often
referred to as “jurisdiction to tax”.
Nexus is determined differently for income taxes and for sales tax
purposes.
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For Income Tax Purposes
In general, nexus is created for income tax purposes if an entity
derives income from sources within the state, owns or leases property
in the state, employs personnel in the state in activities that exceed
"mere solicitation," or has capital or property in the state.
For Sales Tax Purposes
Nexus is determined for sales tax purposes more loosely. Here are
some cases in which a business might have a sales tax nexus in a
state:
If the business has a physical location in the state;
If there are resident employees working in the state;
If the business has property (including intangible property) in the state;
If there are employees who regularly solicit business in the state.
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NEXUS
Sales and Use tax is the most common US tax exposure for Canadian companies doing
business in the United States.
It is imposed by 45 states, 14,000 plus local jurisdictions.
Rules vary from state to state; but rates range from 4 % to 10 % plus
Generally applies to sales of tangible personal property to end used and may apply to
certain services.
Also applies to property brought into the state (Use tax), Use tax is the compliance of the
purchaser.
Non Compliance makes it your gross receipts tax.
The terms Virtual Nexus, Attribution Nexus and Economic Nexus have also begun to
develop;
These are grey areas and as mentioned above, and they vary from State to State:
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U.S. Estate Taxes- Brief
U.S. estate tax applies to the fair market value of the world-wide
property of a U.S. citizen, a Green Card holder and an individual
resident in the U.S. at the time of their death. As well, U.S. estate tax
generally applies to property situated in the U.S. that is owned by
Nonresidents of the U.S. In calculating an individual’s taxable estate,
deductions for debts and certain expenses are permitted. However, for
Canadian residents, the permitted deductions are prorated based on
the value of their U.S. gross assets over their world-wide assets.
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U.S. Estate Taxes- Brief
A Canadian who dies in 2008 owns a Florida condominium worth $600,000 U.S. and
non-U.S. situs assets worth $2.4 million U.S.
In this case, the net U.S. estate tax will be calculated as follows:
Estate Tax on $600,000 U.S.:
Tax on the first $500,000 U.S. $155,800
Tax on balance at 37% 37,000
192,800
Less:
Prorated unified credit
$600,000/$3,000,000 x $780,800 156,160
Net U.S. Estate Tax in 2008 $ 36,640
As you can see from this example, the Canada-U.S. tax treaty only provides partial relief
where the value of a Canadian’s U.S. property is low in relation to the total value of their
estate.
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U.S. Vacation and Rental Homes
The decline in value of U.S. real estate and the relative strength of the
Canadian dollar compared to the U.S. dollar has recently increased the
amount of investment by Canadians in U.S. real estate.
Many techniques can be used to plan for potential purchase of property
and limit the potential U.S. estate tax liabilities:
Being Non-resident alien in U.S.;
Non-recourse Mortgage;
Ownership Alternatives;
Canadian Discretionary Trust.
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Non-resident alien in U.S.
If a U.S. vacation property is held for personal use, a Canadian
resident
who is also a resident or citizen of the U.S. needs not be concerned
about U.S. income taxes or the need to file U.S. income tax return,
unless the property is sold during the lifetime.
If the US property is used to generate rental income, the person paying
the rent is obliged to withhold and remit 30% of the gross rent to the
Internal Revenue service on behalf of the nonresident alien.
The non-resident alien should provide a particular withholding waiver to
its tenant prior to collecting any rent so as to avoid the 30% withholding
above. W-8BEN, W-8ECI and other election with the tax return.
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Non-recourse Mortgage
Non-recourse Mortgage is a financing instrument where the lender’s
security and collection rights are limited to the collateral posted by the
borrower, who is not personally liable for any debt in excess of the
value of collateral.
Non-recourse Mortgage are effective Estate Tax avoidance methods
because any outstanding balance of such a mortgage is deducted from
the fair market value of the US property for purposes of calculating the
Estate Tax liability thereon. As the fair market value of the U.S.
property serves as the base upon which Estate Tax and the available
Unified Credit are calculated, reducing the fair market value of the U.S.
property directly reduces a decedent's Estate Tax liability.
For Canadian tax purposes, interest is generally deductible if the
borrowed funds are used to generate income.
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Ownership Alternatives
Corporation
In the past, many Canadians used a Canadian corporation (known as a
“single-purpose corporation”) to hold personal-use U.S. real estate to
avoid U.S. estate tax on the property. Shares of a Canadian company
are not U.S.-Situs property for U.S. estate tax purposes. As long as the
sole purpose of the corporation was to own the U.S. property and all
expenses related to the property were paid personally by the
shareholders, the Canada Revenue Agency (CRA) would not consider it
The shareholders to have received a taxable benefit for the personal
use of the property. However, using a corporation to hold the property
can increase the total tax on any capital gain realized on the disposition
of the property.
Note: Renting will disqualify the corporation.
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Ownership Alternatives
Personal Ownership
Personal Ownership avoids the cost and inconvenience associated
with
introducing new entities and reporting for them.
Also, it avoids the relatively high U.S. corporate tax rates on income
and capital gains from U.S. property.
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Canadian Discretionary Trust
A Canadian discretionary trust may be a useful way for a wealthy
individual or couple to mitigate their Estate Tax liability. Through the
trust, Estate Tax is deferred until the death of the beneficiaries of the
trust.
The trust uses the parent’s money to purchase the U.S. property. The
parents are generally excluded as beneficiaries of the trust; rather the
parents’ child or children are named. They must conduct themselves
around the trust.
It is generally desirable to avoid generating income and/or capital gains
in the trust because various U.S. and Canadian compliance
obligations,
as well as potential taxable benefits.
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Snowbirds
A Canadian snowbird will be considered a resident alien if spent in
United States:
183 days or more in the current year;
between 31 and 182 days in the current year, he/she may meet the
substantial presence test, as well.
If a Canadian snowbird wants to be exempted from being considered a
non resident alien–there are two possible exemptions you can claim:
a) Exemption under the “Closer Connection Category” of the U.S.
Internal Revenue Code;
b) Exemption under the Canada-U.S. Tax Treaty.
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Transfer pricing
Transfer prices are prices that companies charge for goods, services,
tangible and intangible assets they trade with subsidiaries and similar
controlled entities in foreign markets.
According to the tax law in Canada, United States, and other developed
countries, the proper transfer price is one which two parties dealing at
arm's length would agree to for a certain transaction.
The idea is to force the related companies to sell their goods, services,
tangible and intangible assets to one another at market prices for tax
purposes.
From a Banking perspective this can impact Financial Statements, Covenant
Requirements, have Tax Implications.
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Regulation 105
It requires businesses to withhold 15 per cent of fees, commissions,
and any other amount paid to non-resident contractors for services
rendered in Canada.
The amount withheld is not a final tax, a non-resident can demonstrate
that the withholding is more than their potential tax liability in Canada,
either due to treaty protection or income and expenses, Canada
Revenue Agency may waive or reduce the withholding.
If the required amount is not withheld, the company must pay (on
behalf of the non-resident) the amount plus interest and applicable
penalties.
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Thin Capitalization Rules
Under these rules, interest paid by Canadian corporation on loans
received from non-resident shareholders that own 25 per cent or more
of the shares of the corporation will not be deductible to the extent that
such loans exceed increasingly the equity of the corporation.
In order to be ensured the system remains effective in protecting
Canada’s tax base, the Panel recommended that the current thin
capitalization rules be retained, but that the maximum debt-to-equity
ratio be reduced from 2:1 to 1.5:1, and that scope of the thin
capitalization rules be extended to partnerships, trusts and Canadian
branches of non-resident corporation. For IRS there is no definite thin
capital limitation but 2:1 and 3:1 have been guidelines used in
past.
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Benefits of Cross Border Taxation to Bankers
Being Aware of contemporary issues that concern your clients
Making a statement that you are aware of Global needs of clients;
It is important that Canadian companies take time to plan how to
enter the US and global markets, tax implications will impact there
bottom line.
Ensuring that client is compliant in all tax filings both personal and
corporation.
Reduce exposure to unnecessary penalties, interest and tax costs
that would hurt working capital and covenants.
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Benefits of Cross Border Taxation to Bankers
Ensure client has proper structure to reduce tax costs of international
business
Tax can be a large expenditure, why would a company do
business planning on a pre-tax basis .
Understand cross bordering structuring when it comes to PPSA and
GSA, how to ensure your assets are protected.
Provide Cross Border Financing solution to meet client’s needs.
Provide Cross Border Banking solutions that meet client needs.