U.S. Tax Tips
Feb 10, 2020
As discussed in Part 1, a partner is deemed to be doing business in the U.S. via their interest in the partnership. Partnerships, in general, do not pay tax, the partners do. As such, with respect to a foreign partner the U.S. Congress was (and still is) concerned that once funds leave the United States that the U.S. Internal Revenue Service (IRS) may be unable to enforce payment of the non-resident’s U.S. tax liability. As such, the Internal Revenue Code imposes a withholding obligation on the partnership itself. IRC §1446 states
Jan 27, 2020
Here at Cadesky U.S. Tax Ltd., we receive a lot of inquiries in regards to how to structure a non-resident’s investment into the United States. Many of these investments involve U.S. real property or marketable securities. In addition, we also receive a lot of questions from Canadian advisors and new clients who have held these investments for a number of years but who have never filed any U.S. tax returns, primarily because these investments have not generated any revenue until the underlying investments are being sold.
Jan 15, 2020
On December 20, 2019 President Trump signed into law The Setting Every Community Up for Retirement Enhancement Act (aka the “Secure Act”). A number of authors have described The Secure Act as one of the most dynamic changes to retirement legislation since the Pension Protection Act of 2006. All changes are effective as of January 1, 2020. In particular there are 4 main changes (with respect to pension items)…