CANADIAN TAX PLANNING FOR FOREIGN INHERITANCES
Many immigrants to Canada will ultimately inherit substantial wealth from family members who did not follow them to this country.. Usually, those new Canadians are not aware of the Canadian income tax...
View ArticleRECENT CRA INTERPRETATION REITERATES CANADIAN TAX TREATMENT OF LIECHTENSTEIN...
There are no specific provisions in the Income Tax Act (“the Act”) that deal with foreign foundations. Such entities are commonly formed in such civil law jurisdictions as Luxembourg, Liechtenstein,...
View ArticleCANADIAN TAX IMPLICATIONS OF DISTRIBUTIONS FROM FOREIGN TRUSTS
A Canadian resident who is a beneficiary of a foreign (i.e. non-resident) trust (which generally will include a foreign estate for this purpose) needs to be aware of the Canadian tax implications of...
View ArticleTAX ISSUES FOR CANADIAN EXPATS WITH OFFSHORE TRUSTS
As a general rule, if a Canadian resident (“the contributor”) contributes property to a trust that would otherwise be non-resident (“NRT”), the trust will be a deemed resident trust (“DRT”). A DRT is...
View ArticleHOW CANADIANS CAN (MAYBE) FIX A TAINTED OFFSHORE TRUST
Many affluent immigrants to Canada are beneficiaries of offshore trusts that have been established by family members overseas, either before or after they moved to Canada. With proper care and...
View ArticleCANADIAN FOREIGN ASSET REPORTING ISSUES WITH VACATION PROPERTIES
Thousands of Canadians own vacation properties in foreign jurisdictions, such as the United States, Mexico, Panama, or various Caribbean islands. With the winters in this country, that should be no...
View ArticleBEWARE-THE CRA IS SCRUTINIZING CANADIANS WITH OFFSHORE TRUSTS
A recent lunch with a tax lawyer friend of mine gave me some valuable insights regarding how tough and aggressive the Canada Revenue Agency is getting with Canadians who report substantial...
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