Canada/U.S. Tax Team (CUTT)
Canada is the United States’ leading trade partner, and in recent years the economies of these two countries have become increasingly integrated. Both countries have complex business environments, and trade is regulated by a combination of US and Canadian tax laws, NAFTA and the U.S. Canada Tax Treaty.
The Tax Treaty between the US and Canada has a broad impact on individuals and corporations engaged in cross-border commercial activity. The Fifth Protocol amending the Tax Treaty introduced significant changes to many areas of cross-border tax, including:
- Tax treatment for different legal entities such as LLC’s & Hybrid Entities
- Withholding taxes, including Regulation 102 and Regulation 105 waivers
- Residency & Permanent Establishment for tax purposes
- Taxation of Employee Stock Options
Recent years have also seen major developments in areas other than taxation. The US dollar has fluctuated in value against the Canadian currency, and many businesses and businesses and investors have incurred losses because they did not properly hedge themselves against these currency fluctuations.
In short, a proper understanding of the two business and regulatory environments is a key success factor to entities conducting cross-border business between the US and Canada.
To assist our clients in this area, UHY International has assembled the Canada/U.S. Tax Team (CUTT). CUTT is a group of experienced U.S. and Canadian tax professionals, who work closely with one another to guide businesses in their cross-border ventures.
Areas of CUTT Expertise
- Consideration of integrated tax minimization strategies and repatriation of profits
- Regulation 105 and Regulation 102 withholdings
- Compliance with Federal, State & Provincial tax laws
- Payroll administration and year-end reporting requirements
- Analysis of available corporate tax incentives and government assistance
- Establishing an effective Canada US transfer pricing policy
- Performing transfer pricing analysis
- Sale of a cross-border business
- Cross-border real estate ventures
- Sale of real estate and section 116 withholding issues
- Developing local business & banking contacts
- Preparation of US and Canadian personal income tax returns
- Analysis of the tax ramifications of a cross-border move
- Departure tax
- Expatriate tax planning and preparation
Estates and Trusts
- Cross-border Trust and Estate planning and administration
- Tax planning to minimize exposure to US Estate Taxes
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