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Renouncing US citizenship or giving up a green card in the Gulf: why and how to consider it

US citizenship or permanent resident status allows access to the largest economy in the world. Why would an American citizen living in the United Arab Emirates, or a Saudi Arabian resident with a US “green card,” ever consider giving up US status? Increasingly, the answer is one word: tax.  Unique among global powers, the United States taxes

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Reporting Australian Superannuation Funds as Foreign Trusts for Tax Purposes

When You Don’t Have a Pair of Magical Ruby Slippers Like Dorothy[1] Current US tax laws do not provide any definitive guidance on the US tax classification and treatment of hybrid foreign retirement plans such as an Australian Superannuation Fund (“ASF”).[2] In June 2015, the IRS issued a series of Private Letter Rulings (“PLRs”)[3] to

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Five More Things You Should Know About Major Changes in US Immigration

For anyone paying even moderate attention to the news over the past few years, it will come as no surprise that the Trump administration’s views on immigration have had a significant impact on US immigration policy and procedure, including marked sweeping changes to policies previously supported by the Obama, Bush, and Clinton administrations.  While not

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The Trump Transition Tax’s Impact on Certain Canadians: A Practical Solution for Ottawa to Consider

Every day, it seems, Finance Minister Bill Morneau fields questions about Canada’s international competitiveness considering the recently enacted US tax reforms, which became effective January 1, 2018, by the Tax Cuts and Jobs Act (“TCJA”). Indeed, the TCJA lowered US tax rates and handed out tax breaks to all kinds of entrepreneurs, businesses, and individuals.

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Trust Reporting Rules – Draft Legislation Released

As part of draft legislation released on July 27, 2018, the Department of Finance moves forward with new trust reporting rules that were announced in the 2018 Federal budget. The draft legislation did not contain many surprises. Having said that, the new trust reporting rules will be a big change for many trustees, beneficiaries and protectors of trusts who will now be required to adhere to additional reporting requirements.

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Five Things You Should Know – Cannabis and Travel to the US

It’s no secret that perceptions and laws regarding cannabis have changed significantly in recent years, with medicinal and adult use becoming legal in some form or another in Canada and many states in the US.  While travel to the US a couple of decades ago was easily accomplished with a Canadian driver’s license, the level

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18 Lessons Learned from the Experience of the July 18, 2017 Private Corporation Tax Proposals

On February 27, 2018, the federal government released its annual “budget.” This summary focuses only on the tax measures as it relates to private clients and our related commentary. With the exception of the passive investment proposals as described below, this year’s budget was not all that “meaty.” For the non-technically inclined person, please only read our executive summary. For the technically inclined, enjoy!

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The “Income Sprinkling” Trilogy – V3 of the Tax on Split Income Proposals

When we think about trilogies, our brains often think about movies and not tax proposals. Quick: can you think of any good movie trilogies? There aren’t many. As one movie critic aptly states: Unfortunately, there are few good examples of a solid collective trilogy. Many fall apart on the second or third go-around, often tarnishing

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B.C.’s “Speculation Tax” – Nomenclature at Its Finest

If you are a resident in a province other than B.C. for the purposes of paying income taxes, and you own residential property in Metro Vancouver, the Fraser Valley, the Capital and Nanaimo Regional Districts, or in the municipalities of Kelowna and West Kelowna (the “Target Areas”), you should be paying special attention to the

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