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 did increase increase the “proposed confiscation” of the retained earnings of certain Canadian Controlled Private Corporation, from 12% to 14%.
Renunciations to increase!: Brady (managers's amendment) increase the confiscation of assets of Canadian Controlled Private Corporations from 12% – 15% (5% – 7% for illiquid assets). US move to territorial tax for corps expands US tax territory to Canada https://t.co/yO67NHBNym pic.twitter.com/wm883QSG2j
— Citizenship Lawyer (@ExpatriationLaw) November 9, 2017
See the “Manager’s Amendment” here:
Now back to our regular programming …
How US tax reforms affect cross-border clients – @AdvisorCA: effect on earnings of #CCPC small Canadian corporations https://t.co/oCCGEWyo1I pic.twitter.com/5n6cp2YlpE
— Citizenship Lawyer (@ExpatriationLaw) November 3, 2017
Kudos to Max Reed for his quick analysis of the how the proposed U.S. tax reform bill might affect Canadians citizen/residents who also have hold U.S. citizenship. You will find the bill here. His analysis, which has been widely discussed at the Isaac Brock Society (beginning here) includes provisions that are very damaging to those who are the owners of Canadian Controlled Private Corporations (noting they are also under assault from Messrs Trudeau and Morneau). The damaging provisions are both prospective and retrospective.