A fair amount of Canadian taxpayers spend a substantial period of the year in the United States while retaining their Canadian resident status. New income tax rules in the United States related to the notion of residence play an important rule in the planning of the life of a taxpayer. The first part of this paper focuses on the American legislation in order to warn the taxpayers about the potential income tax consequences of spending time in the United States.The second part of this paper analyses the U.S. income tax legislation related to Canadian taxpayers who invest in U.S. real estate. Should the taxpayer use a corporation to hold the investment? Should that corporation be Canadian or American? These questions trigger a number of poten...
The tax treatment of housing is a central issue of income tax design. The United States tax code, wh...
The Heroes Earnings Assistance and Relief Tax Act of 2008 amended the anti-avoidance provisions of t...
The U.S. and Canadian tax systems are often compared, particularly in Can-ada. The comparison is usu...
Canada is one of the countries depending on foreign investment to a fairly high extent. After some t...
The impact of the United States\u27 Tax Reform Act of 1986 has been significant. The Act has created...
In a world without taxes, investors that take over companies would do so because they expect to be a...
The purpose of this thesis is to examine the impact of the new Canadian Income Tax Act on real estat...
In this paper, the tax and regulatory system applicable to petroleum production in Canada is modeled...
on income paid to investors from the other country. Such taxes act as a tariff on crossborder invest...
This article compares the rules governing the federal income taxation of corporate reorganizations i...
This article compares the rules governing the federal income taxation of corporate reorganizations i...
The new Income Tax Act (S.C. 1970-71, c.63), formely known as Bill C-259, has introduced important c...
"The words "persons" and "taxpayers" as used in the "Income Tax Act" include corporations (section ...
This paper examines Canadian corporate income tax policy, focusing on the implications of internatio...
Note:Recent years have witnessed a growing concern among Canadians about the necessity and desirabil...
The tax treatment of housing is a central issue of income tax design. The United States tax code, wh...
The Heroes Earnings Assistance and Relief Tax Act of 2008 amended the anti-avoidance provisions of t...
The U.S. and Canadian tax systems are often compared, particularly in Can-ada. The comparison is usu...
Canada is one of the countries depending on foreign investment to a fairly high extent. After some t...
The impact of the United States\u27 Tax Reform Act of 1986 has been significant. The Act has created...
In a world without taxes, investors that take over companies would do so because they expect to be a...
The purpose of this thesis is to examine the impact of the new Canadian Income Tax Act on real estat...
In this paper, the tax and regulatory system applicable to petroleum production in Canada is modeled...
on income paid to investors from the other country. Such taxes act as a tariff on crossborder invest...
This article compares the rules governing the federal income taxation of corporate reorganizations i...
This article compares the rules governing the federal income taxation of corporate reorganizations i...
The new Income Tax Act (S.C. 1970-71, c.63), formely known as Bill C-259, has introduced important c...
"The words "persons" and "taxpayers" as used in the "Income Tax Act" include corporations (section ...
This paper examines Canadian corporate income tax policy, focusing on the implications of internatio...
Note:Recent years have witnessed a growing concern among Canadians about the necessity and desirabil...
The tax treatment of housing is a central issue of income tax design. The United States tax code, wh...
The Heroes Earnings Assistance and Relief Tax Act of 2008 amended the anti-avoidance provisions of t...
The U.S. and Canadian tax systems are often compared, particularly in Can-ada. The comparison is usu...