Income Tax Convention involving American and Canadian limited liability companies (LLCs) and unlimited liability companies (ULCs). It examines several articles of the protocol which cover treaty benefits for U.S. individuals who carry or invest on business in Canada via Canadian-formed ULCs and U...
Canada: Limitation on the Elimination of Double Taxation Under the Canada-Brazil Income Tax Treaty This short comment reviews the Tax Court of Canada decision in Société générale valeurs mobilieres inc. v. The Queen, addressing the interpretation of ... D Duff - 《Social Science Electronic Pu...
We are not accountants, but normally, the income you make in Canada will be exempt via tax treaty (assuming you have no permanent establishment in Canada). The reverse is true for Canadians doing business in the US. Check with an accountant to be sure of your tax liabilities though. Howeve...
On June 22, 2023, new mandatory tax disclosure rules in the Income Tax Act (Canada) (the “ITA”) came into force, which expanded the scope of transactions that taxpayers, advisors and investors must report to the Canada Revenue Agency (the “CRA”). The mandatory disclosure rules encompass...
In recent years many "gourment fastfood" franchises have been expanding into Canada, companies like South St. Burger, Five Guys Burgers & Fries. The most recent of this is Nando's, a gourmet chicken franchise from the UK. Proof that you are not a real franchise, until you have expanded ...
Update –… London, UK too I will be in London onWednesday January 17, 2024. Since I am already there, I am happy to connect with London residents who wish to discuss all things related to surviving as a U.S. citizen living outside the USA. The session is: ...
Does the UK have a comparative advantage over Canada, if so what might they be? What would the world be like without government intervention? What is an NOL carry-forward? What is debt funding? What are the rights conferred by a patent? What is the history behind the fight against defores...
The Daily Mail, UK 18th February 2009 An adulterous Spanish woman who conceived three children with her lover has been ordered to pay £177,000 in 'moral damages' to her husband. The cuckolded man had believed that the three children were his until a DNA test eventually proved they wer...
Strong Legal System: “Hong Kong has a legal system second to none. We focus on using the city as a jumping off point for investment into Canada, using the Hong Kong-Canada tax treaty and leveraging off the connections between Hong Kong and Mainland China to facilitate inbound work,” -St...
I have clients in the UK billed in GBP. How do I account for changes in exchange rate between issuing an invoice and it being paid on the balance sheet, without re-writing history in my books? For instance in my own little world I would like to use the exchange rate on the date the...