International taxation in Canada involves complex rules around taxation of non-residents, international transactions, and foreign investments. Residents are taxed on worldwide income and receive credit for foreign taxes paid, while non-residents are taxed on Canadian-source income. Key areas addressed include taxation of non-residents doing business or with investments in Canada, tax treaties which can modify domestic tax rules, and tax implications of Canadians holding foreign investments or moving residency.
This document summarizes various provisions of the Tax Cuts and Jobs Act (TCJA) including:
1) Individual and corporate tax rates that were reduced under the TCJA.
2) Changes to itemized deductions such as capping state and local tax deductions, mortgage interest deductions, medical expense deductions, and suspending some miscellaneous itemized deductions.
3) Strategies like "bunching" deductions, qualified charitable distributions, and investing in Qualified Opportunity Funds to maximize savings under the new tax law.
This chapter discusses gross income and exclusions. It defines gross income for tax purposes and explains when taxpayers recognize income. It discusses the various sources of income, including income from services, property, annuities, and other sources. It also covers the major exclusion provisions that allow taxpayers to exclude or defer certain types of income from gross income, such as municipal bond interest, home sale gains up to $250,000, education-related exclusions, and foreign earned income up to $97,600.
This document provides learning objectives and content about individual income tax computation and tax credits. It covers determining regular and alternative minimum tax liability, computing employment and self-employment taxes, describing types of tax credits including refundable and nonrefundable personal and business credits, and explaining taxpayer filing requirements and penalties. Examples are provided to illustrate concepts like kiddie tax, education credits, and late payment penalties.
This document discusses the concepts of gross income and exclusions under US tax law. It defines gross income as all realized income from any source, unless specifically excluded or deferred. Realization, recognition and the tax benefit rule are explained. Various types of income including income from services, property, annuities, and flow-through entities are described. The document also outlines many exclusion provisions that allow taxpayers to exclude certain types of income from gross income, such as municipal bond interest, capital gains on primary residences, qualified fringe benefits, scholarships and more. Deferral provisions are also briefly mentioned.
There is no limit on the amount one can give annually, but gifts over $15,000 to any one recipient other than a spouse or charity are considered taxable gifts. Donors must file a gift tax return for taxable gifts and such gifts reduce the lifetime gift and estate tax exclusion amount. Completed gifts of property are generally taxed based on fair market value on the date of transfer. Certain transfers like qualified education or medical payments are excluded from gift taxes.
If an individual, partnership, estate, trust, or an S corporation
engages in an activity that is not conducted as a
for-profit business, expenses (other than cost of goods sold)
are not deductible. This rule does not apply to corporations,
other than S corporations. If an activity is considered
a for-profit business, deductions can exceed income, allowing
the resulting loss to offset other income.
The term “fringe benefit” refers to any benefit provided to
an employee that is in addition to money. All benefits provided
to an employee are taxable unless the law specifically
excludes or defers tax on the benefit.
This document summarizes various provisions of the Tax Cuts and Jobs Act (TCJA) including:
1) Individual and corporate tax rates that were reduced under the TCJA.
2) Changes to itemized deductions such as capping state and local tax deductions, mortgage interest deductions, medical expense deductions, and suspending some miscellaneous itemized deductions.
3) Strategies like "bunching" deductions, qualified charitable distributions, and investing in Qualified Opportunity Funds to maximize savings under the new tax law.
This chapter discusses gross income and exclusions. It defines gross income for tax purposes and explains when taxpayers recognize income. It discusses the various sources of income, including income from services, property, annuities, and other sources. It also covers the major exclusion provisions that allow taxpayers to exclude or defer certain types of income from gross income, such as municipal bond interest, home sale gains up to $250,000, education-related exclusions, and foreign earned income up to $97,600.
This document provides learning objectives and content about individual income tax computation and tax credits. It covers determining regular and alternative minimum tax liability, computing employment and self-employment taxes, describing types of tax credits including refundable and nonrefundable personal and business credits, and explaining taxpayer filing requirements and penalties. Examples are provided to illustrate concepts like kiddie tax, education credits, and late payment penalties.
This document discusses the concepts of gross income and exclusions under US tax law. It defines gross income as all realized income from any source, unless specifically excluded or deferred. Realization, recognition and the tax benefit rule are explained. Various types of income including income from services, property, annuities, and flow-through entities are described. The document also outlines many exclusion provisions that allow taxpayers to exclude certain types of income from gross income, such as municipal bond interest, capital gains on primary residences, qualified fringe benefits, scholarships and more. Deferral provisions are also briefly mentioned.
There is no limit on the amount one can give annually, but gifts over $15,000 to any one recipient other than a spouse or charity are considered taxable gifts. Donors must file a gift tax return for taxable gifts and such gifts reduce the lifetime gift and estate tax exclusion amount. Completed gifts of property are generally taxed based on fair market value on the date of transfer. Certain transfers like qualified education or medical payments are excluded from gift taxes.
If an individual, partnership, estate, trust, or an S corporation
engages in an activity that is not conducted as a
for-profit business, expenses (other than cost of goods sold)
are not deductible. This rule does not apply to corporations,
other than S corporations. If an activity is considered
a for-profit business, deductions can exceed income, allowing
the resulting loss to offset other income.
The term “fringe benefit” refers to any benefit provided to
an employee that is in addition to money. All benefits provided
to an employee are taxable unless the law specifically
excludes or defers tax on the benefit.
International Tax and Transfer Pricing TopicsSkoda Minotti
This document provides an overview and agenda for topics related to international taxation and transfer pricing. It discusses general U.S. tax principles, income tax treaties, the foreign tax credit, international filing requirements, and transfer pricing. Specific items covered include the U.S. tax treatment of foreign persons and U.S. persons, anti-deferral regimes like Subpart F and PFIC, and documentation requirements for forms like 5471, 8865, and 8858.
This document summarizes the key tax consequences of home ownership including:
1) Determining if a home is a principal residence, secondary residence, or non-residence for tax purposes.
2) Calculating taxable gain on the sale of a residence and exclusions for principal residences.
3) Limitations on deducting interest expenses and points paid on loans secured by homes.
4) Deductibility of real property taxes and first-time homebuyer credits.
5) Tax treatment of homes used for both personal and rental use.
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.
There are several ways to solve your irs tax troubles, and your tax lawyer can help you decide which solution is best for you.
http://www.irstaxreliefsettlement.com
This document summarizes key concepts around business income, deductions, and accounting methods for tax purposes. It describes the general requirements for deducting business expenses and identifies common deductions. It also explains the concept of accounting periods and describes the accounting methods (cash, accrual, hybrid) available to businesses for determining taxable income and expense deductions. Special business deductions are also identified and examples are provided to illustrate concepts like reasonable compensation, the 12-month rule for prepaid expenses, and accounting for advance payments under different methods.
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.
This document summarizes key aspects of individual income tax calculations in the United States, including:
1) It outlines the basic formula for calculating individual tax liability, including components like gross income, deductions, exemptions, taxable income, tax rates, credits, and payments.
2) It describes the requirements for determining personal and dependency exemptions, including the definitions of a qualifying child and qualifying relative.
3) It explains the different filing statuses individuals can use, including married filing jointly, head of household, and qualifying widow. Examples are provided to illustrate how to determine the proper filing status.
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.
Tax Reform Presentation Overview for July 19th Presentation - Workshop at WHE...hefusa
The document provides an overview of changes to taxation of C corporations and pass-through entities under the Tax Cuts and Jobs Act of 2017. Key points include:
- The corporate tax rate was permanently reduced from 35% to a flat 21% rate.
- A new 20% deduction was introduced for qualified business income from pass-through entities, though it is subject to complex limitations.
- Expensing and bonus depreciation rules were expanded to incentivize business investment.
- Individual tax rates were reduced and the standard deduction was nearly doubled, though many itemized deductions were limited or eliminated.
Rowbotham & Company is a full-service CPA firm with offices in San Francisco and Silicon Valley. The firm provides audit, accounting, and domestic and international tax services to individuals and businesses. The document outlines key tax changes under the new tax act and answers international tax questions, including reporting requirements for foreign accounts and trusts. It also discusses strategies for expatriation and estate/gift tax planning.
The document provides information about tax laws and credits for Idaho residents for 2008. Key points include:
1) A new federal law allows non-itemizers an additional standard deduction for real property taxes up to $500 ($1,000 for joint filers) for 2008. Idaho had not yet conformed to this provision.
2) The grocery credit for Idaho residents was increased to $30-$50 per exemption depending on taxable income.
3) Idaho conforms to various federal tax law changes from 2008 including increased bonus depreciation and Section 179 deductions.
4) Forms and requirements are provided for residents, nonresidents, part-year residents, and military personnel regarding which Idaho
The foreign tax credit intends to reduce the double tax burden that would otherwise arise when foreign source income is taxed by both the United States and the foreign country from which the income is derived.
ADVANCE TAX RELIEF LLC - We Solve Tax Problems
www.advancetaxrelief.com
Call (800)790-8574
BBB Accredited Business
HUSC 3366 Chapter 3 Taxes in Your Financial PlanRita Conley
The document discusses various topics related to taxes and financial planning. It covers the four main types of taxes: taxes on purchases, property, wealth, and earnings. It also discusses how to calculate taxable income and federal income tax liability. This includes determining deductions, exemptions, and tax credits. The document provides an overview of tax planning strategies individuals can use to reduce their tax burden.
This document provides an overview of tax accounting methods and concepts. It discusses the cash method of accounting, which recognizes income when cash is received and expenses when paid. The document provides examples of constructive receipt, where a taxpayer has income even if not yet received in cash. It also briefly mentions the accrual method and hybrid accounting methods. The document appears to be an introductory chapter on tax accounting from a textbook.
Congress has approved H.R. 1 the Tax Cuts and Jobs Act, significantly altering the U.S. tax code. Join us to learn more about what the new legislation means for individuals and businesses, including corporations and pass through entities.
This WEBINAR is an overview about how the Tax Cuts and Jobs Act alters the U.S. tax code for individuals and businesses.
For more in-depth information and personal engagement with our team, we welcome you to join us on Tuesday, January 30th from 9-11am at our Rockville Location, 1445 Research Boulevard, Ground Level Conference Room, Rockville, MD 20850.
Congress has approved H.R. 1 the Tax Cuts and Jobs Act, significantly altering the U.S. tax code. Join us to learn more about what the new legislation means for individuals and businesses, including corporations and pass through entities.
Join us for a conversation about how tax reform impacts individuals and businesses, including corporations and pass through entities.
This document summarizes U.S. tax reporting requirements and rules for 2011 and beyond. It discusses income thresholds for filing requirements, standard deductions, personal exemptions, the foreign earned income exclusion, tax treaty benefits, self-employment taxes, income tax rates, capital gains taxes, the alternative minimum tax, donated IRAs, the surtax on unearned income, Keren Hishtalmut taxes, PFIC rules, child tax credits, additional child tax credits, estate and gift tax exemptions and rates, annual gift tax exclusions, and foreign financial asset reporting including the Foreign Bank Account Report (FBAR), Form 8938, the Foreign Account Tax Compliance Act (FATCA), and its proposed regulations.
This document discusses the allocation and apportionment of expenses and how it affects foreign tax credit benefits. It covers key definitions such as class of income, statutory groupings, and residual groupings. It provides examples of how interest, research and experimental, stewardship, and state taxes and charitable deductions are allocated and apportioned. It also discusses adopting a plan to apportion selling, general and administrative expenses. The document examines how expense apportionment impacts the calculation of foreign source taxable income and the foreign tax credit limitation.
The Legal 500 and The In-House Lawyer Comparative Legal Guide Ireland: Privat...Matheson Law Firm
Private Client Partner, John Gill and Private Client Senior Associate, Maeve Lochrie provide an overview to private client law in Ireland.
The chapter broadly addresses the income and capital taxes regime for private individuals who are resident and / or domiciled in Ireland and highlights certain reliefs for resident non-domiciled individuals and certain reliefs from capital taxes.
The chapter also provides a high-level summary of Irish succession law and the establishment of certain vehicles for transferring and / or safeguarding wealth.
Matheson’s Private Client department provide a relocation service to non-Irish executives and non-Irish individuals relocating to Ireland.
Overview of DTAA Provisions_WIRC_14.05.16 - Harshal BhutaHarshal Bhuta
This document provides an overview of the key provisions contained in Double Taxation Avoidance Agreements (DTAAs). It discusses the typical structure and categories covered in DTAAs such as scope, definitions, taxation of various types of income, methods to eliminate double taxation, and final provisions. For each article, it summarizes the United Nations (UN) Model Convention approach and provides some commentary on issues or differences compared to other models or in Indian DTAAs. The document analyzes important articles related to the taxation of business profits, dividends, interest, royalties, capital gains, independent and dependent personal services.
International Tax and Transfer Pricing TopicsSkoda Minotti
This document provides an overview and agenda for topics related to international taxation and transfer pricing. It discusses general U.S. tax principles, income tax treaties, the foreign tax credit, international filing requirements, and transfer pricing. Specific items covered include the U.S. tax treatment of foreign persons and U.S. persons, anti-deferral regimes like Subpart F and PFIC, and documentation requirements for forms like 5471, 8865, and 8858.
This document summarizes the key tax consequences of home ownership including:
1) Determining if a home is a principal residence, secondary residence, or non-residence for tax purposes.
2) Calculating taxable gain on the sale of a residence and exclusions for principal residences.
3) Limitations on deducting interest expenses and points paid on loans secured by homes.
4) Deductibility of real property taxes and first-time homebuyer credits.
5) Tax treatment of homes used for both personal and rental use.
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.
There are several ways to solve your irs tax troubles, and your tax lawyer can help you decide which solution is best for you.
http://www.irstaxreliefsettlement.com
This document summarizes key concepts around business income, deductions, and accounting methods for tax purposes. It describes the general requirements for deducting business expenses and identifies common deductions. It also explains the concept of accounting periods and describes the accounting methods (cash, accrual, hybrid) available to businesses for determining taxable income and expense deductions. Special business deductions are also identified and examples are provided to illustrate concepts like reasonable compensation, the 12-month rule for prepaid expenses, and accounting for advance payments under different methods.
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.
This document summarizes key aspects of individual income tax calculations in the United States, including:
1) It outlines the basic formula for calculating individual tax liability, including components like gross income, deductions, exemptions, taxable income, tax rates, credits, and payments.
2) It describes the requirements for determining personal and dependency exemptions, including the definitions of a qualifying child and qualifying relative.
3) It explains the different filing statuses individuals can use, including married filing jointly, head of household, and qualifying widow. Examples are provided to illustrate how to determine the proper filing status.
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.
Tax Reform Presentation Overview for July 19th Presentation - Workshop at WHE...hefusa
The document provides an overview of changes to taxation of C corporations and pass-through entities under the Tax Cuts and Jobs Act of 2017. Key points include:
- The corporate tax rate was permanently reduced from 35% to a flat 21% rate.
- A new 20% deduction was introduced for qualified business income from pass-through entities, though it is subject to complex limitations.
- Expensing and bonus depreciation rules were expanded to incentivize business investment.
- Individual tax rates were reduced and the standard deduction was nearly doubled, though many itemized deductions were limited or eliminated.
Rowbotham & Company is a full-service CPA firm with offices in San Francisco and Silicon Valley. The firm provides audit, accounting, and domestic and international tax services to individuals and businesses. The document outlines key tax changes under the new tax act and answers international tax questions, including reporting requirements for foreign accounts and trusts. It also discusses strategies for expatriation and estate/gift tax planning.
The document provides information about tax laws and credits for Idaho residents for 2008. Key points include:
1) A new federal law allows non-itemizers an additional standard deduction for real property taxes up to $500 ($1,000 for joint filers) for 2008. Idaho had not yet conformed to this provision.
2) The grocery credit for Idaho residents was increased to $30-$50 per exemption depending on taxable income.
3) Idaho conforms to various federal tax law changes from 2008 including increased bonus depreciation and Section 179 deductions.
4) Forms and requirements are provided for residents, nonresidents, part-year residents, and military personnel regarding which Idaho
The foreign tax credit intends to reduce the double tax burden that would otherwise arise when foreign source income is taxed by both the United States and the foreign country from which the income is derived.
ADVANCE TAX RELIEF LLC - We Solve Tax Problems
www.advancetaxrelief.com
Call (800)790-8574
BBB Accredited Business
HUSC 3366 Chapter 3 Taxes in Your Financial PlanRita Conley
The document discusses various topics related to taxes and financial planning. It covers the four main types of taxes: taxes on purchases, property, wealth, and earnings. It also discusses how to calculate taxable income and federal income tax liability. This includes determining deductions, exemptions, and tax credits. The document provides an overview of tax planning strategies individuals can use to reduce their tax burden.
This document provides an overview of tax accounting methods and concepts. It discusses the cash method of accounting, which recognizes income when cash is received and expenses when paid. The document provides examples of constructive receipt, where a taxpayer has income even if not yet received in cash. It also briefly mentions the accrual method and hybrid accounting methods. The document appears to be an introductory chapter on tax accounting from a textbook.
Congress has approved H.R. 1 the Tax Cuts and Jobs Act, significantly altering the U.S. tax code. Join us to learn more about what the new legislation means for individuals and businesses, including corporations and pass through entities.
This WEBINAR is an overview about how the Tax Cuts and Jobs Act alters the U.S. tax code for individuals and businesses.
For more in-depth information and personal engagement with our team, we welcome you to join us on Tuesday, January 30th from 9-11am at our Rockville Location, 1445 Research Boulevard, Ground Level Conference Room, Rockville, MD 20850.
Congress has approved H.R. 1 the Tax Cuts and Jobs Act, significantly altering the U.S. tax code. Join us to learn more about what the new legislation means for individuals and businesses, including corporations and pass through entities.
Join us for a conversation about how tax reform impacts individuals and businesses, including corporations and pass through entities.
This document summarizes U.S. tax reporting requirements and rules for 2011 and beyond. It discusses income thresholds for filing requirements, standard deductions, personal exemptions, the foreign earned income exclusion, tax treaty benefits, self-employment taxes, income tax rates, capital gains taxes, the alternative minimum tax, donated IRAs, the surtax on unearned income, Keren Hishtalmut taxes, PFIC rules, child tax credits, additional child tax credits, estate and gift tax exemptions and rates, annual gift tax exclusions, and foreign financial asset reporting including the Foreign Bank Account Report (FBAR), Form 8938, the Foreign Account Tax Compliance Act (FATCA), and its proposed regulations.
This document discusses the allocation and apportionment of expenses and how it affects foreign tax credit benefits. It covers key definitions such as class of income, statutory groupings, and residual groupings. It provides examples of how interest, research and experimental, stewardship, and state taxes and charitable deductions are allocated and apportioned. It also discusses adopting a plan to apportion selling, general and administrative expenses. The document examines how expense apportionment impacts the calculation of foreign source taxable income and the foreign tax credit limitation.
The Legal 500 and The In-House Lawyer Comparative Legal Guide Ireland: Privat...Matheson Law Firm
Private Client Partner, John Gill and Private Client Senior Associate, Maeve Lochrie provide an overview to private client law in Ireland.
The chapter broadly addresses the income and capital taxes regime for private individuals who are resident and / or domiciled in Ireland and highlights certain reliefs for resident non-domiciled individuals and certain reliefs from capital taxes.
The chapter also provides a high-level summary of Irish succession law and the establishment of certain vehicles for transferring and / or safeguarding wealth.
Matheson’s Private Client department provide a relocation service to non-Irish executives and non-Irish individuals relocating to Ireland.
Overview of DTAA Provisions_WIRC_14.05.16 - Harshal BhutaHarshal Bhuta
This document provides an overview of the key provisions contained in Double Taxation Avoidance Agreements (DTAAs). It discusses the typical structure and categories covered in DTAAs such as scope, definitions, taxation of various types of income, methods to eliminate double taxation, and final provisions. For each article, it summarizes the United Nations (UN) Model Convention approach and provides some commentary on issues or differences compared to other models or in Indian DTAAs. The document analyzes important articles related to the taxation of business profits, dividends, interest, royalties, capital gains, independent and dependent personal services.
This document provides an overview of international taxation concepts. It discusses how residency is a key factor in determining tax jurisdiction, as countries either tax worldwide income for residents or only income from domestic sources for non-residents. There can be conflicts when countries define residency differently, such as based on place of incorporation versus management and control, which can lead to double taxation. Treaties aim to resolve such conflicts but different countries take different approaches in their treaties. The concepts of residency, jurisdiction, and relief from double taxation are important aspects of international tax.
This PPT is mainly on the basics of International Taxation which is confusing for many students and many professionals too nowadays. During this evolving world of multinational culture, International Taxation has gained significant importance of which all the professionals should be aware of.
I have tried to compile the concepts of international taxation in this PPT except the concept of Transfer Pricing which in itself is like a whole book.
I have inserted the core concepts which lead to the emergence of International Taxation in India.
The Easiest way to understand International taxation , Concept of Double taxation and its avoidance agreements (DTAA) and its types . Tax implication of activities of foreign enterprise in India: Mode of entry and taxation respectively.
This document provides an introduction to international taxation and tax treaties. It begins with definitions of key concepts like globalization and international taxation. It then discusses tax treaties, including their objectives, evolution, models, and structure. The document outlines the prominent articles in tax treaties, including those related to definitions, distributive provisions, and anti-avoidance measures. It also discusses how tax treaties are interpreted and concepts like permanent establishment. Overall, the document aims to introduce fundamental aspects of international taxation and tax treaty frameworks.
This presentation gives an overview of taxation of non resident indians and gives a basic understanding of Double Taxation Avoidance Agreements between countries. This is meant only for amateurs in the field of taxation and gives only a very basic and bird's eyeview on the subject.
International Taxation – US Citizen and Green Card Holder (Resident Alien)Smart Accountants
With the Tax Season shaking the entire industry, only something valuable should divert your attention. And believe us when we say that our webinar series, which covers a variety of highly engaging topics around U.S Taxation is exactly what you should be focusing on!
This document summarizes some common tax and financial planning challenges for US expats, including:
- Owning and renting real estate while living overseas can involve determining whether expenses are deductible or must be capitalized, and what happens when rental properties are sold.
- The dependent care credit can apply to care provided by non-US citizens, but special reporting may be required. Eligible expenses are limited and the credit is non-refundable.
- The foreign earned income exclusion allows expats to exclude up to $91,400 of foreign earned income per year if they meet residency or presence tests. Proper reporting is complex.
- Foreign bank accounts over $10,000 require reporting to the IRS
With the Tax Season shaking the entire industry, only something valuable should divert your attention. And believe us when we say that our PPT series, which covers a variety of highly engaging topics around U.S Taxation is exactly what you should be focusing on!
ACCT323 Final exam1.Which of the following represents .docxannetnash8266
ACCT323 Final exam
1.
Which of the following represents the largest percentage of state tax revenue?
Sales tax
Individual income tax
Other
Property tax
None of these
2.
Congress recently approved a new, bigger budget for the IRS. What taxation concept evaluates the cost of administering our tax law?
Convenience
Economy
Certainty
Equity
None of these
3.
The city of Granby, Colorado recently enacted a 1.5% surcharge on vacation cabin rentals that will help pay for the city's new elementary school. This surcharge is an example of _______.
A sin tax to discourage undesirable behavior
A government fine
An earmarked tax
Both A and C
None of these
4.
If Susie earns $750,000 in taxable income, how much tax will she pay as a single taxpayer for year 2012?
$231,639.50
$262,500.00
$239,261.00
$236,435.00
None of these
5.
Which of the following is not considered a primary authority?
Tax Court case.
Regulation.
Revenue Ruling.
Tax service.
None of these.
6.
Which of the following is not a factor that determines whether a taxpayer is required to file a tax return?
rev: 03_21_2013_QC_28372
Filing status.
Taxpayer's gross income.
Taxpayer's occupation.
Taxpayer's age.
None of these.
7
.
Corporations are required to file a tax return only if their taxable income is greater than:
$0.
$1,000.
$600.
$750.
None of these. Corporations are always required to file a tax return.
8.
Lavonda discovered that the U.S. Circuit Court of Appeals for the Federal Circuit has recently issued a favorable opinion with respect to an issue that she is going to litigate with the IRS. Lavonda should choose which of the following trial courts to hear her case:
Tax Court only.
U.S. Court of Federal Claims only.
U.S. District Court only.
Tax Court or the U.S. District Court.
Tax Court or the U.S. Court of Federal Claims.
9.
Jason's employer pays year-end bonuses each year on December 31. Jason, a cash basis taxpayer, would prefer to not pay tax on his bonus this year (and actually would prefer his daughter to pay tax on the bonus). So, he leaves town on December 31, 2011 and has his daughter, Julie, pick up his check on January 2nd, 2012. Who reports the income and when?
Julie in 2011
Julie in 2012
Jason in 2011
Jason in 2012
None of these
Top of Form
10.
Investing in municipal bonds to avoid paying tax on interest earned and to earn a higher after-tax yield is an example of:
conversion
tax evasion
timing
income shifting
None of these
Bottom of Form
11.
Which of the following increases the benefits of income deferral?
increasing tax rates
smaller after-tax rate of return
larger after-tax rate of return
smaller magnitude of transactions
None of these
12.
Which of the following is an example of the timing strategy?
A corporation paying its shareholders a $20,000 dividend
A parent employing her child in the family business
A taxpayer gifting stock to his children
A cash-basis busi.
This document outlines various national taxes imposed in the Philippines, including income tax, estate tax, value-added tax, excise taxes, customs duties, and other taxes. It provides details on income tax rates and calculations, defining terms like gross income, taxable income, deductions, exemptions, and who is required to file an income tax return.
The document outlines the timeline and process for passing the Tax Cuts and Jobs Act of 2017 in the U.S. Congress. It then provides a high-level overview of some of the major provisions introduced in the new tax law, including lower corporate tax rates, limitations on interest expense deductibility, immediate expensing, changes to net operating loss rules, new FDII rules, lowered rates for pass-through entities, related party anti-hybrid rules, and the new Base Erosion and Anti-Abuse Tax (BEAT). The provisions are complex due to existing rules layered on top of the new rules, and regulations will be needed to provide further guidance. Tax planning flexibility will be important given elements that
Introduction to Taxation of Foreign Investment in U.S. Real EstateSmart Accountants
This webinar introduces some of the most important tax issues that non-US investors in U.S. real estate should consider.
You will learn:
- Introductions to US Real Estate investment by Foreign Investor
- FDAP income (Not trade or business income)
- Effectively Connected Income (ECI)
- Foreign Investment in Real Property Tax Act of 1980 (FIRPTA)
- Choice of proper investment structure and tax planning
- Tax Implications for:- Rental income tax- Capital Gain Tax on the eventual disposition of property- Estate/Gift tax consequences
- Other consideration- Anonymity – Nondisclosure of the identity- Assets protection- The simplicity of the structure balances against complexity costs.
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.
The document provides an overview of training for volunteers to prepare city tax returns for low-income individuals. It outlines details on eligible clients, priorities of quality returns, covered cities, how to prepare returns in TaxWise software, tax rates, common deductions and credits, examples of calculating tax liability, and filing procedures.
The document discusses various tax issues that Swedish companies may face when doing business in the United States, including establishing a permanent establishment, setting up a subsidiary or branch office, corporate income tax rates, and determining resident alien vs. nonresident alien status for tax purposes. Key considerations include whether business income is attributable to a permanent establishment located in the US, how branches and subsidiaries are taxed differently, federal and state corporate income tax rates, and tests for determining resident alien status.
Canadian Tax System & Doing Business in Ontario - February 25, 2013 Seminar (...Sonja Chong FCA, TEP
This document provides information about the Canadian tax system and doing business in Ontario. It discusses who is liable to pay tax in Canada, the concept of worldwide income for tax residents, and definitions of foreign affiliates and controlled foreign affiliates. It also summarizes considerations for business structure selection, tax rates for businesses in Ontario, and tax planning strategies for new tax residents. Record keeping requirements and types of tax and information returns are outlined.
Here are the key points regarding the tax treatment of the Shanghai branch of Anchor Banking Corporation:
1. Anchor Banking Corporation is a domestic corporation organized under Philippine laws. As such, it is subject to Philippine income tax on its worldwide income.
2. The Shanghai branch, though located abroad, is not a separate legal entity. It is merely an extension of the domestic corporation.
3. Income earned by the Shanghai branch from its banking operations in China constitutes business income attributable to Anchor Banking Corporation.
4. Such income should have been included in computing the annual income tax liability of Anchor Banking Corporation in its income tax return filed with the BIR.
5. Excluding the P20 million net
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.
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.
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.
The document outlines key aspects of the US individual income tax system. It discusses tax rates and taxable income calculations for individuals, including standard deductions, exemptions, and tax credits. It also covers taxation of capital gains and losses, as well as special tax provisions for homeowners, students, charitable donations, and more. Tax rates are provided for single, married, head of household, and other filing statuses.
While federal income tax aims to be progressive by taxing higher incomes at higher rates, the overall tax system is not truly progressive due to various factors. Federal income tax accounts for about two-thirds of taxes paid, but state taxes are often regressive, taking a larger share from low and middle incomes. Some states have no income tax, instead relying on other taxes like sales tax. The interaction of federal, state, and local taxes determines the true burden faced by income groups.
2. overview Taxation of non-residents with Canadian investments or business dealings Tax treatment of international transactions with Canadian residents Taxation of Canadian residents with foreign investments Basic application of tax treaties on taxation of various sources of income Application of tax compliance requirements for above 2
3. International tax Canadians hold a significant amount of foreign investments and vice versa Tax consequences as a result of these holdings Highly complex area and many practitioners specialize in this area 3
4. liability Concept of residency revisited Citizenship is not relevant Residents are taxed on worldwide income Receive credit for taxes paid in foreign jurisdictions Non residents are liable for tax 4
5. Non residents The Act provides that individuals who are not resident but are taxable on the following Was employed in Canada Carried on a business in Canada Disposed of taxable Canadian property At any time during the year calculated in accordance with Division D 5
6. Definition includes Real or immovable property in Canada Property used or held in ECE or inventory of a business Shares of a corporation resident in Canada that are not listed Shares of NR corporation that are not listed if during the prior 60 months surpassed certain Canadian asset thresholds Shares of a Canadian resident corporation that are listed where within prior 60 months owned not less that 25% of the shares Interest in a partnership Capital interest in Canadian resident trust Units of a Canadian resident trust Units of mutual funds Interest in nonresident trusts if certain thresholds surpassed Interest in or option in respect of the above 6
7. Definition extensions Canadian resource properties Timber resource properties Income interest in a Canadian resident trust Certain partnership agreements Canadian life insurance policies 7
8. Most common Real property Property used in business Unlisted shares of private corporation 8
9.
10. Part year residents Income, deductions and credits A person may be part-time resident in only two conditions Where a Canadian resident leaves (clean break) When a foreign resident arrives (fresh start) Income based on time in Canada Some credits are prorated Personal tax, age, disability Others are claimed in full Pension, Canada employment, medical, charitable Public transit, fitness, adoption expenses 10
11. Example Aaron Levy immigrated to Canada during 2008, arriving on August 15. He earned salary in Israel of C$35,000 before coming to Canada. On arriving, he went to work for the City of Winnipeg, where he earned $15,000 in employment income. He also attended the University of Winnipeg on a part-time basis for four months and his tuition fees were $900 What is his tax situation? 11
15. Deemed acquisition on entry Taxpayers deemed to dispose of immediately before entry and acquiring at FMV Ensures that taxed only on gains made after becoming resident 15
16. Example When Aaron came to Canada he had 5,000 shares of a pubco on the NYSE. He paid US$18 per share and FMV when he came to Canada was US$24 and the forex rate was 1.02 What is his ACB for tax purposes? If he sold them in 2008 for C$32 (assume forex rate is 1.03) per share, what is his taxable amount? 16
17. Solution 17 Aaron is deemed to have acquired the shares at US$24, or US$120,000 in total. ACB when he enters Canada is C$24.48 or C$122,400 On disposition he includes taxable gain as follows:
18. other Deemed rules do not apply to the following: Taxable Canadian property Inventory of a business carried on in Canada ECP of a business in Canada Salary deferral arrangements, RPPs, RRSPs, rights to CPP and OAS 18
19. Deemed disposition on leaving Canada When a taxpayer gives up Canadian residency, there is a deemed disposition at FMV for both capital and non capital This ensures that Canada receives fair share of taxes on accrued gains before departure Latest of: Date individual leaves Canada Spouse or dependents leave Canada Individual becomes resident of another country 19
20. Example Carol Ann Thomas emigrated from Canada this year. At the time she left, she owned 500 shares of XYZ Ltd, a listed company. FMV was $20 and ACB $8 What is Carol Ann’s Canadian tax position on these shares? 20
22. exemptions Real property in Canada Property of a business carried on in Canada Pensions, RRSPs etc Properties if short term resident (less than 60 months in a 10 year period) Property of a returning nonresident where taxpayer elects to unwind the deemed disposition 22
23. Non residents Income earned in Canada by non residents Was employed in Canada Carried on a business in Canada Disposed of taxable Canadian property Need to file tax return Exempt from filing if: No tax is payable under Part I Non resident does not owe tax from prior years Disposed of excluded property (includes treaty-protected property) 23
24. Determinations Employment income Same criteria as residents Contractor vs employee argument again Source deductions may be required Business income Issue of residency (same criteria as permanent establishment) Use of facilities Maintenance of goods for sale Purchase of goods for sale advertising 24
25. example A US corporation Tellco Inc employs three employees who live and work in Canada. The sales employees work from home offices. Tellco does not have an office or other facility in Canada. The employees are paid monthly salaries and quarterly commissions based on sales volume. The employees solicit sales from Canadian customers. The customers order products directly from the US company online or by phone. Goods are shipped directly from the US warehouse to Canadian customers. Is Tellco carrying on a business in Canada? Does Tellco have a permanent establishment in Canada? Does Tellco have a withholding requirement for Canadian employees? 25
26. Issue 1 Tellco is offering product for sale in Canada through a servant (employee) and would be considered to be carrying on business in Canada under domestic law. 26
27. Issue 2 Tellco would be deemed to have a permanent establishment in Canada, if the employees negotiate and habitually conclude contracts in Tellco’s name. As long as the sales contracts are concluded in the US, Tellco would not have a permanent establishment in Canada. The Convention overrides Canadian tax law. 27
28. Issue 3 Source deductions are required for payments of salary, wages or other remuneration. Remuneration includes commissions paid to an officer or employee. Tellco must withhold and remit prescribed amounts to the Receiver General for the Canadian employees. Assuming that the employees are residents of Canada, Canadian personal tax returns will be filed and the withholdings will reduce the taxes payable on the returns 28
29. Branch tax Imposed on non Canadian corporations carrying on business in Canada through separate entity not incorporated in Canada 25% in addition to Part I tax Paid on branch income not retained in Canada Tax treaty with US limits rate to 5% 29
30. Example 30 International Links Inc is a telecommunications company incorporated in the US with a December 31 year end. It began operating one small pilot project office in Toronto in 2007 in addition to its 52 US offices. The corporation is not resident in Canada; the office is considered a permanent establishment. Taxable income from operations are listed. What is the corporate tax liability?
32. Withholding taxes Non residents liable for tax Part XIII of the Act requires a resident who pays or credits certain amounts to non residents to withhold 25% unless otherwise stated in tax treaty Part XIII is different from Part I – one or the other is paid Common types of income: Management fees Interest paid or payable to NAL person Estate or trust income Rents and royalties Pension benefits RRSP payments Deferred profit sharing plan payments Annuity payments Taxable dividends and capital dividends 32
33. discussion Janet Smith is about to emigrate from Canada. She has $50,00 in her RRSP What are her alternatives in connection with the RRSP? 33
34. solution Janet could collapse her RRSP prior to leaving Canada. In this case, the RRSP would be included in her income in her final Canadian tax return and taxed at her marginal rate. Alternatively, she could collapse her RRAP after leaving Canada, paying 25% withholding tax. Need to choose the approach which will produce the lesser tax 34
35. Rental income The 25% may be punitive as it is applied to GROSS rental income. There may be mortgage payments etc that are funded by the rental income Can elect to file a return and report income and expenses and needs to elect to pay tax on the net income, within 6 months. 35
36. example Jack Lajoha is a resident of Spain but has a rental property in Canada. The gross rents are $1500 monthly and are collected by his agent Tom Kelly. From the rental income, Tom pays his agent fee, mortgage, property taxes and maintenance of $14,400. Available CCA on the property will be $5,000 for 2008. On average, there is about $300 a month net cash flow available. How does Jack account for the rental income in Canada? 36
37. solution 37 Tom is required to deduct 25% of the gross rents and remit to CRA as withholding tax. The withholding tax of $375 exceeds the average monthly net cash flow. Jack can choose to file and receive a refund of the withholding tax over the actual tax required
38. Tax treaties Broken down into Articles which govern how various items are treated: Article IV – residency (tie breaker article) Article V – permanent establishment Article XI – interest Article XIII – capital gains (gains of US residents are exempt from tax in Canada unless real property or a share in Canadian resident corporation; gains of Canadian residents are exempt from US law) 38
39. Cross border transactions Transfer pricing A situation where a Canadian taxpayer buys or sells products or services to a related non-resident person where pricing may be an issue Canadian importer might arrange with a supplier that any goods purchased be first sold to a wholly owned subsidiary in a tax haven. The wholly owned sub then resells to Canco at a price that includes a profit to the sub. As the sub is in a tax haven, any profits made are not taxed. In essence, the profit has been shifted out of Canada Adjustments will apply if a taxpayer and NAL NR participate in a transaction where the terms and conditions differ from those in an arms length transaction Penalty of 10% if adjustment is required Penalty will not apply if reasonable effort made to price the tranaction 39
40. Cross border transactions Thin capitalization Where NR shareholders own 25% or more of votes or FMV of a Canadian corporation Prevents shareholders from removing profits from corporation by way of tax free interest rather than dividends A(B – (2 x C))/B A = interest otherwise deductible B = average of outstanding debts C = sum of beginning retained earnings for the year, the average of the NR share of beginning contributed surplus, and the average of beginning PUC for the NR shares 40
41. example Canada Corp is held 100% by non residents. The existing equity in the company is $200,000 (sum of equity, PUC and contrib surplus). Interest paid on a $1 million debt was $125,000 What is the impact if any on the thin capitalization of the company? 41
42. solution Use the formula to limit the interest amount A(B – (2 x C))/B 125,000 interest – (1,000,000 – (2 x 200,000))/1,000,000 $75,000 Canada Corp can deduct $50,000 (125,000 interest paid - $75,000 non deductible under 18(4)) 42
43. Information reporting Required to report annually if own foreign property with value of greater than C$100,000 If yes, need to report what kind of income was received, the cost of property, and location of property. Failure to file is $500/month penalty up to 24 months ($12,000) 43