Tax Tips for Home-Based Business Owner
If you are having home business, it is quite natural that the topic of tax deduction comes up. We all are aware of this fact that tax deduction is not possible if you are an employee. But the most important
13.3 U.S Interpretation of the Treaty
13.3.1 [a] Taxation of Gains by Non-resident Aliens and Foreign Corporations The United States generally imposes a flat 30 percent tax, collected by withholding, on the gross amount of U.S. source investment income payments including non-capital gains earned by NRA individuals
What is an arm’s Length Transaction?
In an arm’s length transaction persons will act in their separate interest. It is a transaction that reflects ordinary commercial dealings between parties acting in their separate interests. Related persons are not considered to deal with each other at arm’s length. Persons
13.2 Explanation & Interpretation of Article XIII Under Canadian Law
13.2.1 Canadian Taxation of Gains of Non-Residents Canada does not impose tax on gains from the disposition of property by a non-resident other than the disposition of taxable Canadian property. Accordingly, as a first step of the analysis, one has to
13.1 Introduction to Article XIII – Gains
Article XIII generally deals with the taxation of capital gains realized by residents of Canada or the U.S. that may be also taxed in the other State. The general rule dealing with the allocation of jurisdiction to impose tax on the
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
Article XII – Royalties
12.0 Treaty Article - Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. - Royalties any also be taxed in the Contracting State in which they arise, and
Cross Border Travelers
There are three types of people who travel to U.S from Canada. We may call first category of people as vacationers. These are short term visitors to the U.S who like to take a break from Canadian winters. These people are
11.3 Explanation & Interpretation of Article XI under U.S. Law
11.3 Explanation & Interpretation of Article XI under U.S. Law 11.3.1 U.S Domestic Taxation of Interest Paid to Canadian Residents 11.3.1[a] Definition of Interest Interest has been broadly defined by the courts as representing the cost of using borrowed money, the amount which
Net Investment Income Tax (NIIT)
The NIIT is a tax at the rate of 3.8% that is applied to many different investments and is assessed on trusts, estates and individuals if their income is above the statutory threshold amounts. Individuals who are exempt from Medicare taxes,