TCJA and Expanding the definition of and number of "Controlled Foreign Corporations" subject to Subpart F

As goes the number of “Controlled Foreign Corporations“, so goes the size of the U.S. tax base. The “messaging” was that the United States was moving to a system of […]

Part 43 – The 1996 Treasury Regs, 2017 TCJA And The Looting Of Canadian Controlled Private Corporations

Punishing U.S. citizens who live outside the United States As Tax Residents Of Canada "The Little Red Transition Tax Book" – Everything you need to know about the 965bmandatory repatriation […]

Treasury 26 CFR ยง 301.7701-2 – Business entity definitions discriminate against Canadian Controlled Private Corporations

Synopsis: The power to regulate is the power to destroy! That's why the regulatory process should require careful consideration of how and to whom regs apply. It's time for Treasury […]

US Treasury proposes that foreign income subject to high foreign tax be excluded from definition of #GILTI

In general – Good News For American Entrepreneurs Abroad … On Friday June 14, 2019 US Treasury proposed in Notice 2019-12436 that any foreign income earned by Controlled Foreign Corporations […]

Part 1: CCPCs – Why the Government of Canada is attacking the use of Canadian Controlled Private Corporations as personal pension plans

Introduction I have previously written about the “Worldwide trend of attacking the use of corporations as a way to reduce or defer taxation for individuals“. This is a continuation of […]

US tax reform bill appears to confiscate 12% (updated to 14%) of retained earnings of certain Canadian Controlled Private Corporations

Update November 9, 2017 Today Chairman Brady concluded the “Mark Up” period of his proposed tax legislation. The “Mark Up” period contained NO move to “territorial taxation” for individuals. It […]

The worldwide trend of attacking the use of corporations as a way to reduce or defer taxation for individuals

Introduction – The war against corporations and the shareholders of those corporations Corporations as entities that are separate from their shareholder/owners As every law students knows, a corporation is a […]

Extradition Is One Way That Changes In Another Country’s Tax Laws May Change Your Tax Relationship With The US

Prologue It's not only changes in US law that affect taxpayers but also changes in laws of other countries. Examples: enforcement (treaties), whether tax is owed (Subpart F) and how […]