U.S.-Canadian Dual Taxation Pitfalls: Reporting Issues and Planning Opportunities for U.S. Taxpayers

Navigating Tax Treaties to Minimize Tax on Passive Income and Pass-Through Income

Recording of a 110-minute CPE webinar with Q&A


Conducted on Thursday, April 27, 2017
Recorded event now available


This webinar will provide tax advisers with a thorough and practical guide into the tax reporting requirements and planning opportunities for U.S. taxpayers with earnings or assets in Canada, as well as Canadian citizens with U.S. tax reporting obligations. The panel will discuss U.S. tax law and treaty provisions designed to avoid or mitigate dual taxation, describe Canadian residency and expatriation rules, and detail the U.S. reporting and payment obligations specific to passive income as well as Canadian trade or business activity. The webinar will also provide useful information on tax reporting of cross-border trust ownership.

Description

The Canada-U.S. border is the longest contiguous international border on earth. The geographical and demographic similarities between the two countries contribute to the world’s largest trade relationship between two countries. Given these harmonious and long-standing relations, Canadian resident taxpayers frequently get caught up in the U.S. income tax system, and vice versa.

A critical component of this cross-border business activity is avoiding dual taxation on income and gains. The U.S. and Canada have a comprehensive tax treaty system that addresses most dual taxation concerns but, as in all international planning, tax advisers must understand the particular provisions to avoid an unpleasant tax bill—or maybe two.

Among the planning challenges for cross-border activities is navigating the tax treatment of LLCs and other U.S. disregarded entities. Canadian owners of U.S. LLC shares could face dual tax layers. Tax advisers for clients using LLCs will need to engage in careful planning on both sides of the border.

Other areas of concern in U.S.-Canadian tax planning include treatment of passive income and tax considerations of cross-border pension ownership, contributions and withdrawals. Hovering over all these concerns are the extensive U.S. tax reporting requirements imposed on taxpayers with U.S. filing obligations.

Listen as our experienced panel provides comprehensive and practical guidance on navigating U.S.-Canada cross-border tax planning and reporting issues.

Outline

  1. U.S.-Canada Tax Treaty overview and dual tax mitigation provisions
  2. Treatment of U.S.-based LLCs and pass-through entities in cross-border situations
  3. Passive and unearned income treatment
  4. U.S. tax reporting requirements of Canadian-sourced investments
  5. Limitation of benefit provisions

Benefits

The panel will discuss these and other important topics:

  • What are the tax treaty provisions for mitigating dual taxation on ownership of cross-border LLCs and other pass-through entities?
  • Limitation of benefits clauses and provisions in U.S.-Canada Income Tax Treaty
  • Key risks and challenges of passive/unearned income in cross-border situations
  • U.S. reporting requirements of Canadian-sourced investment

Learning Objectives

After completing this course, you will be able to:

  • Determine when a non-resident might have a taxable presence in the U.S. or Canada
  • Recognize the tax treatment for Canadian citizens owning owning an interest in a U.S. entity
  • Discern the tax implications of U.S. taxpayers owning shares in ULCs in Canada
  • Identify key provisions of the U.S.-Canada Income Tax Treaty
  • Decide U.S. reporting requirements of Canadian-sourced investments
  • Identify tax planning opportunities to avoid double taxation and minimize the overall effective tax rate across the two countries

Faculty

Grant Gilmour, International Tax Partner
Gilmour Group CPAs, Vancouver, B.C.

Mr. Gilmour is a corporate tax advisor. His practice focuses on corporate clients in manufacturing and distribution industries that sell products internationally. He has a vast knowledge of tax planning, international tax issues and scientific research and development tax credits.

C. Edward Kennedy, Jr., CPA, JD
Brady Ware & Company, Atlanta

Mr. Kennedy has more than 34 years of experience dealing with a variety of international tax matters, specializing in tax consulting services to a wide variety of clients ranging from closely held companies to multi-national businesses. His expertise includes domestic and foreign income and social security tax planning, tax compliance for individuals and corporations, tax treatment of incentive compensation plans, international assignment program administration, and international assignment policy design. Prior to joining the firm, he served as KPMG LLP's US firm lead for international social security matters. 


EA Credit

Enrolled Agent credit processing is available for an additional fee per person.

EA Processing $5.00


Recordings

Recorded Event

Includes full event recording plus handouts.

Note: Self-study CPE and EA credits are not offered on recorded events.

Recorded Webinar Download $147.00

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Recorded Audio Download (MP3) $147.00

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DVD (Slide Presentation with Audio) $147.00 plus $9.45 S&H

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IRS Approved Provider

Strafford is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

Program Materials

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Program Materials

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Strafford is a NASBA CPE sponsor and our live webinars qualify for CPE credits. They offer you a high quality, cost effective, and convenient CPE option, with no lost travel time or expenses.

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EA Credit

Strafford is an IRS approved continuing education provider and this course is approved for 2 enrolled agent (EA) credit hours.

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Customer Reviews

Excellent seminar! It was efficient and the important topics were covered at just the right pace; no time was wasted covering information that the participants already knew.

Rhonda G. Williams, CPA

Barraclough & Associates

I loved the tools and handouts. Every CPE class should offer these kind of tools.

Jackie Meyer

Sample and Bailey

I appreciated the flow of the information offered and the ease at which I could follow the handouts.

Larry Bruck

WISS & Company

I purchased the conference a few minutes after it began and the customer service rep was very helpful and got me signed up and logged into the conference very quickly.

Joanna Johnston

Savas Greene & Company

I liked the fact that there was more than one person presenting the material. It's nice to hear multiple perspectives.

Matt Bristow

Cover & Rossiter

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Strafford webinars are backed by our 100% Unconditional Money-Back Guarantee: if you are not satisfied with any of our products, simply let us know and get a full refund. For more information regarding complaints and refunds, please contact us at 1-800-926-7926 ext 10. Complaints regarding this program can be submitted via the course evaluation found in the “Thank you” e-mail at the end of the course.