The Internal Revenue Service (IRS) is increasing its focus on reporting of foreign financial accounts by U.S. persons. Despite recent protests by Finance Minister Jim Flaherty on the matter, the changes seem like they are going to go ahead. There are potentially significant implications that representatives should advise their US clients about. Put simply, just… Continue Reading
Category Archives: Tax and Trusts
Certainty of Intention and Immigration Trusts
The Federal Court and Federal Court of Appeal decisions in Antle v. Canada suggest that such professionals should make sure that their clients understand the nature of what a trust is before establishing an immigration trust.… Continue Reading
Residence Under the Canada-Russia Tax Treaty
We often have clients approach us asking how they can immigrate to Canada without become tax residents. There are a variety of ways to do this, and the recent Tax Court of Canada decision in Denisov v. The Queen highlights one issue that those interested in not being tax-resident need to be prepared to address.… Continue Reading
Am I a Tax Resident in Canada or China?
A person who is a Canadian tax resident must pay income tax on his/her worldwide income. As previously noted in this blog, people who try to evade paying taxes in Canada on income earned abroad face heavy penalties.… Continue Reading
Immigrant Investor Fined For Tax Evasion
On July 15, 2010, the Tax Court of Canada declared that S Korki, an Immigrant Investor from Iran, would have to pay gross negligence penalties for failure to fully disclose income. In the 2002 and 2003 taxation years, Mr. Korki declared a net income of $19,100 and $22,312 respectively. After carrying out a Net Worth… Continue Reading