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In our previous article “U.S. Tax Law: FATCA & it’s Impact on Canadians and the International Community“, we provided an overview of the US Foreign Account Tax Compliance Act (FATCA) and how the U.S. wanted multinational (non-U.S.) banks, financial institutions, and governments of various countries to comply with this law. The article also covered the...
With an increasing number of Canadian citizens/residents working in the U.S. and an increasing number of U.S. citizens/residents working in Canada, it is important that all taxpayers familiarize themselves with the “Social Security Totalization” agreement. The “Social Security Totalization” agreement came into effect in the 1980s, and is a way of providing social security protection...
The Construction or Installation Projects Exception To The Permanent Establishment Article of the Canada-U.S. Tax Treaty Generally maintaining a fixed place of business in Canada is one thing that creates an income taxable connection to Canada. However, there is an exception contained in Article V of the Canada –U.S. Tax Treaty. In Paragraph 3, the...
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