Article 12.3 Explanation & Interpretation of Article XII Under U.S. Law
12.3.1 U.S. Taxation of Outbound Royalty Payments 12.3.1[a] Definition of Royalties The Code generally defines the term “royalty” by enumerating the kinds of property that generate royalty income. For Example, the sourcing rules in the Code refer to income for the use
Cross border tax consultant – Best friend for multinational companies!
To start a multinational company is surely a huge and daring dream but of course not impossible. Some systematic techniques need to be adopted in this case. Firstly, one must remember that developing a multinational company is not similar to
Hire a good consultant before compromising your relaxation to save tax!
Paying tax is a duty for every upstanding citizen. Paying unnecessary tax is not. Often, paying those unnecessary taxes may ruin your plans of going on a vacation, or having a fun trip with family and friends. Sometimes, it’s important
Rich or Poor You Still Need to Pay Your Taxes
If someone comes up to you and tells that they have hired an accountant for doing their taxes, you might look at them in a whole new light. They must be particularly wealthy, right? Their tax situation must be complicated.
Estate Planning in Canada
In this blog we will talk about different aspects of estate planning in Canada Wills are a primary tool in Canada to govern your estate affairs. In U.S. living trusts are common because they are “flow through” entities taxed at your personal rates.
A good tax accountant permits you to file your taxes easier!
Filing of income tax is a nightmare for many. In most cases, people want to file their income tax smoothly without hassle but are unable to do so. In that case, having a good tax accountant is of utmost importance.
Calculating Foreign Tax Credit in Canada
Calculation of foreign tax credit in Canada depends upon source of foreign income. Foreign tax credits are available for business income taxes and non-business income taxes. Taxpayer needs to categorize the income based on where and how the income was
Article 12.2.2 Canadian Interpretation of the Treaty
12.2.2[a] Article XII(1) – Residence – Based Jurisdiction to Tax Article XII(1) plays an important jurisdictional function by confirming the right of the residency State to tax royalties arising from sources in the source State and paid to a resident of
Article 12.1 and 12.2
12.1 Introduction The article on royalties accords to both Canada and the U.S. the right to each Contracting State to tax its residents on royalty income received by those residents. The article generally limits the taxation by the source country to
Top 2 Tax Liabilities for Canadian Snowbirds
In the tax season, Canadian snowbirds who spend considerable time in USA have to be careful about their tax liabilities. There are numerous regulations regarding the tax that they have to pay. It is always a good idea to be