John Richardson
This is a complex problem -
in the spirit of helping people understand the context and unfairness of
this, here is a summary of what is going on:
1. A Canadian resident individual creates a Canadian Controlled Private Corp.
2. That CDN corp may make some profits.
3. If those profits are paid out to the individual, the individual pays taxes on his personal tax return (wherever he is required to file a return).
4. If the profits earned by the Corp are not paid out to the individual they are (1) taxed to the corp in Canada. The "after tax money" remains in the corp for future investment, or to be distributed to the individual later. Note that in Canada the money is not taxed to the individual until the money is distributed to the individual.
5. Canadians with U.S. citizenship also have to file U.S. tax returns. Those returns disclose existence of the CCPC and the amount of earnings that have not been paid out by the corp.
6. Money left in the corp (to be distributed later) was fully disclosed to the USA, but was NOT subject to US tax when earned. I repeat it was NOT (under US law subject to taxation when it was earned).
7. USA is claiming the right to (1) impose tax on money earned by the corp by (2) pretending that the money was actually earned by the individual (who never received it) - creating fake income!
8. Therefore, this is about (1) the USA imposing retroactive tax on (2) money that was not subject to U.S. tax when earned (3) by pretending that the money was distributed to the CDN shareholder (4) when the money was not distributed.
9. It will expose the individual to double tax in the USA and Canada.
USA is (1) creating fake income (2) imposing real taxation on fake income (3) imposing taxes before Canada can tax it and (4) stealing from Canada.
1. A Canadian resident individual creates a Canadian Controlled Private Corp.
2. That CDN corp may make some profits.
3. If those profits are paid out to the individual, the individual pays taxes on his personal tax return (wherever he is required to file a return).
4. If the profits earned by the Corp are not paid out to the individual they are (1) taxed to the corp in Canada. The "after tax money" remains in the corp for future investment, or to be distributed to the individual later. Note that in Canada the money is not taxed to the individual until the money is distributed to the individual.
5. Canadians with U.S. citizenship also have to file U.S. tax returns. Those returns disclose existence of the CCPC and the amount of earnings that have not been paid out by the corp.
6. Money left in the corp (to be distributed later) was fully disclosed to the USA, but was NOT subject to US tax when earned. I repeat it was NOT (under US law subject to taxation when it was earned).
7. USA is claiming the right to (1) impose tax on money earned by the corp by (2) pretending that the money was actually earned by the individual (who never received it) - creating fake income!
8. Therefore, this is about (1) the USA imposing retroactive tax on (2) money that was not subject to U.S. tax when earned (3) by pretending that the money was distributed to the CDN shareholder (4) when the money was not distributed.
9. It will expose the individual to double tax in the USA and Canada.
USA is (1) creating fake income (2) imposing real taxation on fake income (3) imposing taxes before Canada can tax it and (4) stealing from Canada.
@John Richardson I see that
you are back professing much in CBC yet you or you lawyer buddies don't
call me back or answer your emails since 2015. Methinks as a lawyer you
are trying to make something so simple to me seem complex for your own
personal benefit N'esy Pas?
http://www.cbc.ca/news/politics/trump-tax-repatriation-canadian-1.4779747
David Raymond Amos @DavidRayAmos
Oh My My Now tha ou Minister Morneau has stepped up to the plate perhaps I should call this blog Round TWO N'esy Pas?
http://davidraymondamos3.blogspot.com/2018/08/need-i-say-i-was-delighted-to-see-cbc.html
http://www.cbc.ca/news/politics/trump-tax-repatriation-morneau-1.4783936
David Raymond Amos @DavidRayAmos
Need I say I was delighted to see CBC use theToronto lawyer John Richardson's thoughts against Trump and FATCA etc
http://davidraymondamos3.blogspot.com/2018/08/need-i-say-i-was-delighted-to-see-cbc.html
http://www.cbc.ca/news/politics/trump-tax-repatriation-canadian-1.4779747
Canadian residents hit by Trump tax dealt a new blow
Experts say proposed U.S. regulations could violate the Canada-U.S. tax treaty
· CBC News · Posted: Aug 13, 2018 4:00 AM ET
Comments
Commenting is now closed for this story.
Commenting is now closed for this story.
Denis VanHumbeck
At least the U.S goes after the wealthy tax avoiders unlike Canada.
Ken Michel
@Denis VanHumbeck Please read
the article. None of these people avoided their taxes. They all paid
Canadian corporate income tax.
John Oaktree
@Denis VanHumbeck
Huh... the people getting hurt by this huge Trump tax grab are average Canadians who just happen to be dual citizens.
Tell me - why doesn't Donald Trump honour his international agreements??
BTW - the rich elite billionaires are enjoying a HUGE tax cut from Trump. You know Donald Trump - he's listed in the Panama Papers as a tax avoider several times...
Huh... the people getting hurt by this huge Trump tax grab are average Canadians who just happen to be dual citizens.
Tell me - why doesn't Donald Trump honour his international agreements??
BTW - the rich elite billionaires are enjoying a HUGE tax cut from Trump. You know Donald Trump - he's listed in the Panama Papers as a tax avoider several times...
@Denis VanHumbeck
Wasn't Harper caught fêteing KPMG deal by signing them up as consulting agence to rewrite Canadian tax laws?
Yup! There it is....
https://www.cbc.ca/news/business/harper-government-partnered-with-industry-group-battling-cra-over-kpmg-case-1.3257994
Wasn't Harper caught fêteing KPMG deal by signing them up as consulting agence to rewrite Canadian tax laws?
Yup! There it is....
https://www.cbc.ca/news/business/harper-government-partnered-with-industry-group-battling-cra-over-kpmg-case-1.3257994
@Robert Lee Oh My My Methinks
whereas you won't believe me you should ask Minister Diane
Lebouthillier or the CBC what I know about KPMG et al N'esy Pas?
Dave Carey
As an individual (born and
raised in Canada) that happened to live and work in the US for 15 years
then retired and came back home to live off my pensions earned in both
countries, I'm waiting for the next small step to be taken - that is
taxing individuals as well as corporations. I happen to pay a lot of
taxes in both Canada and the USA and the Canada - US tax treaty is the
only thing that makes that somewhat bearable. Apparently though it
isn't worth the paper it's written on. What a sad pathetic country the
USA has become under Trump!
David Amos
@Dave Carey Methinks the lawyer Richardson and many others know why I called Kevyn Nightingale and left a voicemail N'esy Pas?
Neil Gregory
Once again the USA has proved
that it can NOT be trusted to live up to the provisions contained in
the treaties it has signed. So, the REAL questions are:
- WHY would Canada sign ANY new treaty, including a new NAFTA deal with them?
- WHY does ANY country think we can still trust them to keep ANY other treaty - NATO, NORADE etc?
- WHY would Canada sign ANY new treaty, including a new NAFTA deal with them?
- WHY does ANY country think we can still trust them to keep ANY other treaty - NATO, NORADE etc?
@Neil Gregory
It has more to do with the Trump admin. Not the US.
Crazy Conservative Contracts.
It has more to do with the Trump admin. Not the US.
Crazy Conservative Contracts.
Content disabled.
David Amos
@Neil Gregory WHY would Canada sign ANY new treaty, including a new NAFTA deal with them?
Beats me
Beats me
Content disabled.
David Amos
@David Amos I would love CBC to explain why they blocked that comment
David Amos
@Robert Lee "It has more to do with the Trump admin. Not the US."
Methinks Trump speaks for the US on foreign affairs N'esy Pas?
Methinks Trump speaks for the US on foreign affairs N'esy Pas?
Aala Shariati Saravi
…those who look like us,
speak like us, share borders with us, share ideologies with us, speak
the same language, may after all, not be our friends...
David Amos
@Aala Shariati Saravi Methinks according to Mr Trump we have not settled the War of 1812 yet N'esy Pas?
steve wilson
So wealthy Canadians who were
shopping for yet another tax credit in their zeal to avoid paying any
tax at all have ironically found themselves on the hook for MORE taxes.
Good, the culture of the wealthy avoiding their share of taxes at all costs needs to end! This may be the only thing Trump does I end up applauding.
Good, the culture of the wealthy avoiding their share of taxes at all costs needs to end! This may be the only thing Trump does I end up applauding.
David Amos
@steve wilson Methinks you celebrate Trump's achievement you should Google the following N'esy Pas?
Trump Cohen Amos NAFTA FATCA TPP
Trump Cohen Amos NAFTA FATCA TPP
Charles Beale
One more reasons for
Canadians to take their business, their travel and their cash elsewhere.
Trump is turning the US into a fortress that will eventually be viewed
by the world as an unfriendly alien nation.
David Amos
@Robert Lee Methinks we should talk about what is not reported on by anyone N'esy Pas?
Robert Lee
Yup! That's what means!
Anyone who voted for this chump can now rest easy, sit back and marvel over the destruction they have brought forth by placing a madman in the highest political office in the entire world.
Look at the control Ford is trying to wrest from Canada's largest city. It'll be constant chaos as city councilors juggle between doing their job and fighting with provincial MPPs.
Vote Conservatives and get Machiavellian despots.
Anyone who voted for this chump can now rest easy, sit back and marvel over the destruction they have brought forth by placing a madman in the highest political office in the entire world.
Look at the control Ford is trying to wrest from Canada's largest city. It'll be constant chaos as city councilors juggle between doing their job and fighting with provincial MPPs.
Vote Conservatives and get Machiavellian despots.
@Robert Lee
Indeed I was thinking the same thing, did Ford actually instigate that whole allegation thing, and get Brown removed so he could just move in??
Indeed I was thinking the same thing, did Ford actually instigate that whole allegation thing, and get Brown removed so he could just move in??
David Amos
@Karen King Methinks not one soul would expect you to vote for Conservatives in order to get Machiavellian despots N'esy Pas?
John Richardson
Just to summarize how this "so called" tax works: Here is the "Readers Digest" Version.
1. A Canadian resident individual creates a Canadian Controlled Private Corp.
2. That CDN corp may make some profits.
3. If those profits are paid out to the individual, the individual pays taxes on his personal tax return (wherever he is required to file a return).
4. If the profits earned by the Corp are not paid out to the individual they are (1) taxed to the corp in Canada. The "after tax money" remains in the corp for future investment, or to be distributed to the individual later. Note that in Canada the money is not taxed to the individual until the money is distributed to the individual.
5. Canadians with U.S. citizenship also have to file U.S. tax returns. Those returns disclose existence of the CCPC and the amount of earnings that have not been paid out by the corp.
6. Money left in the corp (to be distributed later) was fully disclosed to the USA, but was NOT subject to US tax when earned. I repeat it was NOT (under US law subject to taxation when it was earned).
7. USA is claiming the right to (1) impose tax on money earned by the corp by (2) pretending that the money was actually earned by the individual (who never received it) - creating fake income!
8. Therefore, this is about (1) the USA imposing retroactive tax on (2) money that was not subject to U.S. tax when earned (3) by pretending that the money was distributed to the CDN shareholder (4) when the money was not distributed.
9. It will expose the individual to double tax in the USA and Canada.
USA is (1) creating fake income (2) imposing real taxation on fake income (3) imposing taxes before Canada can tax it and (4) stealing from Canada.
1. A Canadian resident individual creates a Canadian Controlled Private Corp.
2. That CDN corp may make some profits.
3. If those profits are paid out to the individual, the individual pays taxes on his personal tax return (wherever he is required to file a return).
4. If the profits earned by the Corp are not paid out to the individual they are (1) taxed to the corp in Canada. The "after tax money" remains in the corp for future investment, or to be distributed to the individual later. Note that in Canada the money is not taxed to the individual until the money is distributed to the individual.
5. Canadians with U.S. citizenship also have to file U.S. tax returns. Those returns disclose existence of the CCPC and the amount of earnings that have not been paid out by the corp.
6. Money left in the corp (to be distributed later) was fully disclosed to the USA, but was NOT subject to US tax when earned. I repeat it was NOT (under US law subject to taxation when it was earned).
7. USA is claiming the right to (1) impose tax on money earned by the corp by (2) pretending that the money was actually earned by the individual (who never received it) - creating fake income!
8. Therefore, this is about (1) the USA imposing retroactive tax on (2) money that was not subject to U.S. tax when earned (3) by pretending that the money was distributed to the CDN shareholder (4) when the money was not distributed.
9. It will expose the individual to double tax in the USA and Canada.
USA is (1) creating fake income (2) imposing real taxation on fake income (3) imposing taxes before Canada can tax it and (4) stealing from Canada.
David Amos
@John Richardson Methinks you should recall our last conversation N'esy Pas?
Bill Baird
If you have this problem the
answer is simple. Just join Space Force, there will be a complete tax
deduction. You might have to spend some time in space, but, unless you
have bone spurs that shouldn't be a problem.
Robert Lee
@Bill Baird
Machiavellian bully. Don't believe for a second that Trump is winning.
There is more destruction and disruption than anything else.
If the PM caves to the demands, Trump will come at us for more concessions.
Stand tall!
Machiavellian bully. Don't believe for a second that Trump is winning.
There is more destruction and disruption than anything else.
If the PM caves to the demands, Trump will come at us for more concessions.
Stand tall!
David Amos
@Robert Lee Methinks your Machiavellian rhetoric has become a little boring N'esy Pas?
David Sampson
Back in the day, when Yahweh
was in creation mode, s/he turned to the top angel dude and said:
“Gabriel, I'm going to fashion a country with magnificent mountains,
rivers, lakes, oceans on three sides, extensive forests, vast mineral
wealth, prairies, a multitude of wildlife, a variety of climates — and
I'm going to call this land, ‘Canada.’”
“But, Lord,” Gabriel replied, “why are you being so generous toward this ‘Canada?’” “Ahh, but Gabriel, wait until you see the neighbors I’m going to give them!”
“But, Lord,” Gabriel replied, “why are you being so generous toward this ‘Canada?’” “Ahh, but Gabriel, wait until you see the neighbors I’m going to give them!”
David Amos
@David Sampson Methinks his top Angel dude was Lucifer N'esy Pas?
Don Luft
Well when did Trump ever give
a hoot for an international agreement or treaty? NAFTA, the Paris
Agreement, the Iran deal, , the Outer Space Treaty - it doesn't matter
to Trump. He's rolling back emission standards on cars and wants to
increase the use of coal. which will have international repercussions
for increased carbon emissions
He's only been in power for 19 months and the harm he's done is colossal.
He's only been in power for 19 months and the harm he's done is colossal.
Ron Vollans
@Don Luft
Hillary has been targeted by Republicans for 30+ years, and never once has their accusations resulted in criminal charges, never mind trials and convictions. Blind hate and blatant l's ruined her, not her own actions.
Hillary has been targeted by Republicans for 30+ years, and never once has their accusations resulted in criminal charges, never mind trials and convictions. Blind hate and blatant l's ruined her, not her own actions.
David Amos
@Ron Vollans "Blind hate and blatant l's ruined her, not her own actions."
I disagree
I disagree
http://www.cbc.ca/news/politics/trump-tax-repatriation-morneau-1.4783936
· CBC News · Posted: Aug 14, 2018 4:00 AM ET
John Richardson
David Amos
Jennifer McIsaac
When I ran my company, I regularly took money out of my company and put it into an RSP for my retirement rather than leaving it in my company. In this way the tax was deferred but it was in my name not the company's.
I have not done the calculations tax-wise as to whether keeping money in a company would save tax but I always thought it was a riskier way to save for the future as corporation taxes change with different governments and economic times.
It seems now that US citizens have been caught out by such a tax change in the US. It seems highly unreasonable to me, but those are the risks you take by storing money in your corporation.
Trump Cohen Morneau NAFTA FATCA TPP Amos
Neil Austen
Canada talking with U.S. about Trump tax: Morneau
Retroactive repatriation tax hitting thousands of Canadian residents
Comments
Commenting is now closed for this story.
Commenting is now closed for this story.
John Richardson
This is a complex problem -
in the spirit of helping people understand the context and unfairness of
this, here is a summary of what is going on:
1. A Canadian resident individual creates a Canadian Controlled Private Corp.
2. That CDN corp may make some profits.
3. If those profits are paid out to the individual, the individual pays taxes on his personal tax return (wherever he is required to file a return).
4. If the profits earned by the Corp are not paid out to the individual they are (1) taxed to the corp in Canada. The "after tax money" remains in the corp for future investment, or to be distributed to the individual later. Note that in Canada the money is not taxed to the individual until the money is distributed to the individual.
5. Canadians with U.S. citizenship also have to file U.S. tax returns. Those returns disclose existence of the CCPC and the amount of earnings that have not been paid out by the corp.
6. Money left in the corp (to be distributed later) was fully disclosed to the USA, but was NOT subject to US tax when earned. I repeat it was NOT (under US law subject to taxation when it was earned).
7. USA is claiming the right to (1) impose tax on money earned by the corp by (2) pretending that the money was actually earned by the individual (who never received it) - creating fake income!
8. Therefore, this is about (1) the USA imposing retroactive tax on (2) money that was not subject to U.S. tax when earned (3) by pretending that the money was distributed to the CDN shareholder (4) when the money was not distributed.
9. It will expose the individual to double tax in the USA and Canada.
USA is (1) creating fake income (2) imposing real taxation on fake income (3) imposing taxes before Canada can tax it and (4) stealing from Canada.
1. A Canadian resident individual creates a Canadian Controlled Private Corp.
2. That CDN corp may make some profits.
3. If those profits are paid out to the individual, the individual pays taxes on his personal tax return (wherever he is required to file a return).
4. If the profits earned by the Corp are not paid out to the individual they are (1) taxed to the corp in Canada. The "after tax money" remains in the corp for future investment, or to be distributed to the individual later. Note that in Canada the money is not taxed to the individual until the money is distributed to the individual.
5. Canadians with U.S. citizenship also have to file U.S. tax returns. Those returns disclose existence of the CCPC and the amount of earnings that have not been paid out by the corp.
6. Money left in the corp (to be distributed later) was fully disclosed to the USA, but was NOT subject to US tax when earned. I repeat it was NOT (under US law subject to taxation when it was earned).
7. USA is claiming the right to (1) impose tax on money earned by the corp by (2) pretending that the money was actually earned by the individual (who never received it) - creating fake income!
8. Therefore, this is about (1) the USA imposing retroactive tax on (2) money that was not subject to U.S. tax when earned (3) by pretending that the money was distributed to the CDN shareholder (4) when the money was not distributed.
9. It will expose the individual to double tax in the USA and Canada.
USA is (1) creating fake income (2) imposing real taxation on fake income (3) imposing taxes before Canada can tax it and (4) stealing from Canada.
@John Richardson I see that
you are back professing much in CBC yet you or you lawyer buddies don't
call me back or answer your emails since 2015. Methinks as a lawyer you
are trying to make something so simple to me seem complex for your own
personal benefit N'esy Pas?
Jennifer McIsaac
When I ran my company, I regularly took money out of my company and put it into an RSP for my retirement rather than leaving it in my company. In this way the tax was deferred but it was in my name not the company's.
I have not done the calculations tax-wise as to whether keeping money in a company would save tax but I always thought it was a riskier way to save for the future as corporation taxes change with different governments and economic times.
It seems now that US citizens have been caught out by such a tax change in the US. It seems highly unreasonable to me, but those are the risks you take by storing money in your corporation.
David Amos
@Jennifer McIsaac Methinks
Trumps knows that I once had a company too as do the RCMP, FBI, CRA and
IRS. I am a Canadian citizen only. However I do have legal status as a
Permanent US Resident who is married to a Yankee and the Proud Father of
two adult children who possess duel citizenship status. Hence for the
benefit of my children I have had concerns with FATCA when Obama dreamed
it up and before Morneau was ever elected. If anyone doubts me they
should at least Google the following before attempting to argue me
N'esy Pas?
Trump Cohen Morneau NAFTA FATCA TPP Amos
Jennifer McIsaac
@David Amos
Yes indeed. I agree with you about FATCA.
Yes indeed. I agree with you about FATCA.
Neil Austen
I'm just happy the Liberals
are fiscally responsible. Spending on infrastructure in the beginning to
pull Canada out of the recession the Conservatives drowned Canada in
and then when the economy recovered, started to spend wisely and now
showing over $3 billion surplus in the beginning of this year.
Unlike Conservative Harper who drowned Canada in record debt of 184 billion and then in his last year hid $50 billion of it with accounting tricks and claimed a false balance budget.
Unlike Conservative Harper who drowned Canada in record debt of 184 billion and then in his last year hid $50 billion of it with accounting tricks and claimed a false balance budget.
mo bennett
@Neil Austen energizer bunny, anyone?
Neil Gregory
@William Ben
That LCP koolaid is almost identical to the CPC koolaid you guzzle.
That LCP koolaid is almost identical to the CPC koolaid you guzzle.
David Amos
@Neil Austen Methinks you act
like a bot. You were way off topic yesterday with exactly the same
comment which also made to the top as the most liked. Very Strange N'esy
Pas?
http://www.cbc.ca/news/politics/premiers-governors-stowe-monday-1.4783736
http://www.cbc.ca/news/politics/premiers-governors-stowe-monday-1.4783736
David Amos
@mo bennett You noticed too N'esy Pas?
David Amos
@Neil Gregory True
Neil Gregory
@Roy T. Gilroy
Isn't it interesting how so many right-wing, Conservative posters resort to personal attacks on other when they have nothing intelligent to say on a topic.
Isn't it interesting how so many right-wing, Conservative posters resort to personal attacks on other when they have nothing intelligent to say on a topic.
David Amos
@Neil Gregory Methinks everyone would agree that the left wingnuts do exactly the same N'esy Pas?
Rob Kov
@Neil Austen what a grossly inaccurate statement.
In 2008 Canada was considered one of the toughest economies to weather the financial crisis, and our banking system was praised and considered the gold standard of the world. We managed to recover quickly without an excessive amount of stimulus and return to business as usual in no time.
They also started the year with a surplus... it doesn't mean they will end it with one. They think we will end this year with an $18.1 billion dollar deficit...
https://www.theglobeandmail.com/politics/article-federal-government-starts-the-year-with-32-billion-surplus/
In 2008 Canada was considered one of the toughest economies to weather the financial crisis, and our banking system was praised and considered the gold standard of the world. We managed to recover quickly without an excessive amount of stimulus and return to business as usual in no time.
They also started the year with a surplus... it doesn't mean they will end it with one. They think we will end this year with an $18.1 billion dollar deficit...
https://www.theglobeandmail.com/politics/article-federal-government-starts-the-year-with-32-billion-surplus/
David Amos
@Rob Kov "In 2008 Canada was considered one of the toughest economies to weather the financial crisis"
Methinks you forgot that Hrper bailed out our Banksters too N'esy Pas?
https://www.cbc.ca/news/business/banks-got-114b-from-governments-during-recession-1.1145997
Methinks you forgot that Hrper bailed out our Banksters too N'esy Pas?
https://www.cbc.ca/news/business/banks-got-114b-from-governments-during-recession-1.1145997
Rob Kov
@David Amos yes he did bail
out the banks, which was proper, we also made money on those loans to
the banks so it was win win. I am normally against this type of action
but at least it worked this time.
https://www.forbes.com/2008/12/11/canada-banking-crisis-oped-cx_re_1211elliott.html#76ad0c732e50
https://www.forbes.com/2008/12/11/canada-banking-crisis-oped-cx_re_1211elliott.html#76ad0c732e50
David Amos
@Rob Kov Do you understand
why I sued the Crown and ran against the Conservatives, the Liberals and
all the other parties five times thus far? In a nutshell methinks you
have no clue as to who I am N'esy Pas?
Jim McAlpine
For all the people on here stating "Let them pay their fair share of tax" you should at least have a working understanding of how the tax system works. These individuals DO pay tax on this income as it is taxable when it is paid out of the corporation to them. As well, they are taxable on the income in the US AFTER it is paid to them, but it is eligible to a foreign tax credit just as any other income is by virtue of the tax treaty.
What Trump is trying to do is tax that income before it's paid to them, and regardless of whether they pay tax on the income in Canada. That is double taxation. Think of it this way. How would you feel if you had your pension taxed while it's being accrued, and then after you receive it?
David Amos
@Jim McAlpine "For all the
people on here stating "Let them pay their fair share of tax" you should
at least have a working understanding of how the tax system works."
I concur Methinks we should go back and review the reasons for the creation of the Federal Reserve Bank and the IRS over a hundred years ago N'esy Pas?
I concur Methinks we should go back and review the reasons for the creation of the Federal Reserve Bank and the IRS over a hundred years ago N'esy Pas?
Karen King
@David Amos
many Canadians will take offense to your continual mis spelling, clearly it is intentional, as a anglophone even I find it annoying, very disrespectful.
many Canadians will take offense to your continual mis spelling, clearly it is intentional, as a anglophone even I find it annoying, very disrespectful.
David Amos
@Karen King Methinks that
many snobby anglophones and even you must realize by now that I don't
care what you think about my Chiac Trust the French folks I know around
Fundy understand why N'esy Pas?
Rick Wier
@Karen King not to mention downright stupid
Lawrence Aaluuluuq (RedWhite)
@David Amos
I -want- to unravel that undignified mess you call a comment, but I can't be bothered to.
I -want- to unravel that undignified mess you call a comment, but I can't be bothered to.
David Amos
@Lawrence Aaluuluuq (RedWhite) Methinks I would be a fool to believe you in light of your prior insults N'esy Pas?
Jim S Powers
Trump breaks an agreement between US and Canada and the Cons attack the liberals
incredible how the alt right keep going in the wrong direction
incredible how the alt right keep going in the wrong direction
Content disabled.
David Amos
David Amos
@Erika Kreis Methinks many of
the comments are largely just Trolls creating spin either for the left
or the right's benefit N'esy Pas?
Karen King
@Erika Kreis
as Lawarence also posted:
As long as -this- is who Conservatives decide they are, I will vote AGAINST them every single time until they re-learn their [expletive deleted] roots.
as Lawarence also posted:
As long as -this- is who Conservatives decide they are, I will vote AGAINST them every single time until they re-learn their [expletive deleted] roots.
David Amos
@David Amos Methinks I just proved my point once again N'esy Pas?
Stan Cox
How much time, money and effort is expended around the world in response to trump's poor;y thought-out and uninformed policies?
Imagine what we could be doing instead, if this man hd not been given the power he clearly cannot handle and does not deserve!
How much of the offshore money controlled by Apple or Microsoft has returned to the US?
Imagine what we could be doing instead, if this man hd not been given the power he clearly cannot handle and does not deserve!
How much of the offshore money controlled by Apple or Microsoft has returned to the US?
Jim McAlpine
@Stan Cox - or worse, change
the tax rules 30 years retroactively. Hell, imagine the outcry by Cons
if Trudeau did that to Canadians? The hypocrisy is astounding.
Don Osmond
@Stan Cox
Serioiusly?
DId you read the article before posting?
Evidently not.
Serioiusly?
DId you read the article before posting?
Evidently not.
David Amos
@Jim McAlpine YUP
David Amos
@Don Osmond Methinks reading is not necessary when someone is writing spin for their favourite political party N'esy Pas?
Jack Spratt
So our snake is going to talk to their snake, wonder if Morneau and family have skin in the game?
David MacKinnon
@Jack Spratt
I think you will discover a number of ministers are dual citizens and several have skin in the game.
I think you will discover a number of ministers are dual citizens and several have skin in the game.
David Amos
@David MacKinnon Methinks everything is political and its always about the money N'esy Pas?
keith stanley
Unfortunately the Democrats
went with Hillary who was clueless about the growing anger and angst
amomg the blue collar voters in the mid west . If Bernie Sanders was the
Nominee ,Trump would have lost the Election
David Amos
@keith stanley "If Bernie Sanders was the Nominee ,Trump would have lost the Election"
I agree However the Banksters would never allow that to happen and obviously didn't N'esy Pas?
I agree However the Banksters would never allow that to happen and obviously didn't N'esy Pas?
michael flinn
The CBC continues to state
this effects "thousands of Canadian residents". What is the basis for
this ongoing statement of "fact"? Have CBC reporters examined
"thousands" of American or dual citizen's tax returns?
David Amos
@michael flinn "The CBC continues to state this effects "thousands of Canadian residents".
Methinks its because it does N'esy Pas?
Methinks its because it does N'esy Pas?
michael flinn
@David Amos And your thinking - like that of the CBC - would be based on what facts exactly?
David Amos
@michael flinn Methinks
everybody knows that I back my words in my lawsuits in Canada and the
USA since 2002 and what I said while running for public office five
times thus far. Anyone can Google the following N'esy Pas?
David Amos Federal Court
David Amos Federal Court
Sally Ride
Any bets Morneau will find a
solution for these thousands of Canadian residents while ignoring the
other millions of Canadian taxpayers?
Norman Neil
@Sally Ride
I'll take that bet. And give you 10:1 odds as well.
I'll take that bet. And give you 10:1 odds as well.
David Amos
@Sally Ride Methinks there is
no way that Morneau can fix anything in a year with Trump overseeing
the circus south of the 49th. Many folks would take bets that he won't
be the Minister of Finance anymore in a year or so after the election of
the 43rd Parliament N'esy Pas?
Karen King
@David Amos
N'esy Pas? keep that up and you will be mostly ignored.
N'esy Pas? keep that up and you will be mostly ignored.
David Amos
@Karen King Methinks it is you who is afraid of being ignored N'esy Pas?
Joseph Cluster
The political party of Canada
has little to do with what the United States wants to do tax wise with
their citizens. It would make little difference if our gov't was red,
blue, orange, or green as the people in this equation have chosen to
live here(so they claim)-keep their own citizenship as well-registering a
business in another country to take advantage of paying less taxes in
the country of origin.
David Amos
@Joseph Cluster Methinks that
many would agree when it comes to Banking, Taxation and War we are
hooked at the hip with the Yankees N'esy Pas?
Robert Lee
Remember that tax cheating guy at Harper's Conservative rally?
Ya, that guy...
https://nationalpost.com/news/canada/angry-tory-who-called-reporters-lying-pieces-of-s-says-he-did-nothing-to-shape-anyones-views-of-conservatives
Every time some some story about tax evasion comes up I think of how many conservative senators got away scott free of any jail time. When all was said and done $23 million was spent on the Duffy inquiry, and now there's still a pending court case he filed against Harper and the government of Canada.
https://www.cbc.ca/news/politics/auditor-general-michael-ferguson-breaks-down-23m-cost-of-senate-audit-1.3108276
Ya, that guy...
https://nationalpost.com/news/canada/angry-tory-who-called-reporters-lying-pieces-of-s-says-he-did-nothing-to-shape-anyones-views-of-conservatives
Every time some some story about tax evasion comes up I think of how many conservative senators got away scott free of any jail time. When all was said and done $23 million was spent on the Duffy inquiry, and now there's still a pending court case he filed against Harper and the government of Canada.
https://www.cbc.ca/news/politics/auditor-general-michael-ferguson-breaks-down-23m-cost-of-senate-audit-1.3108276
David Amos
@Robert Lee Methinks you forgot this very enlightening article N'esy Pas?
https://www.cbc.ca/news/business/harper-government-partnered-with-industry-group-battling-cra-over-kpmg-case-1.3257994
https://www.cbc.ca/news/business/harper-government-partnered-with-industry-group-battling-cra-over-kpmg-case-1.3257994
Scott Stephens
Of course Billy is protecting his 1%ers.
David Amos
@Scott Stephens YUP
Al. C Hill
Trump has to pay for all his
spending someways and repatriation of monies was in his campaign...those
caught in this better get ready to write their cheque
David Amos
@Al. C Hill Methinks FATCA was dreamed up under Obama Trump is just embellishing it N'esy Pas?
Canadian residents hit by Trump tax dealt a new blow
Experts say proposed U.S. regulations could violate the Canada-U.S. tax treaty
Thousands of Canadian residents hit
hard by a retroactive tax signed into law by U.S. President Donald Trump
have been dealt another blow, CBC News has learned.
Newly proposed regulations issued by the U.S. Treasury Department and the Internal Revenue Service threaten to increase their tax hit.
"You have to almost empty out your company and pay a lot of Canadian tax to avoid the U.S. tax," said Kevyn Nightingale, a partner with the accounting firm MNP.
Kevyn
Nightingale, a partner in the MNP accounting firm, says the proposed
regulations will increase the tax hit for many Canadian residents.
"It turns a very bad situation into the virtual liquidation of a corporation," said Toronto lawyer John Richardson.
A 'Transition Tax' introduced by the Trump administration was intended to discourage U.S. multinationals from leaving vast sums in foreign subsidiaries. But the tax is also hitting Canadians with U.S. or dual citizenship who have companies incorporated in Canada.
While many of those affected had hoped to use a longstanding U.S. tax deduction to take some of the sting out of their tax bills, the proposed regulations — contained in a guidance document from Treasury and the IRS issued last week — will allow only a portion of that deduction.
Some experts say the proposed regulations may also violate a Canada-U.S. tax treaty which is supposed to prevent double taxation.
"My answer is likely yes — that the IRS guidance does violate the tax treaty," said Max Reed, a Vancouver-based cross-border tax lawyer with SKL Tax.
The new, 249-page guidance document is the latest twist in a complicated tale that some tax experts have described as a "nightmare."
In December, Trump signed a sweeping tax reform bill into law. It included the Transition Tax, also known as the Repatriation Tax, which was meant to get big American multinational companies like Apple and Microsoft to stop parking billions of dollars in foreign subsidiaries.
As a result, many Canadian residents with U.S. or dual citizenship — particularly those who have used their small corporations to save for their retirements — are facing tax bills amounting to hundreds of thousands of dollars on all of the retained earnings in their corporations going back to 1986. Some bills run into the millions.
While the tax is being levied on money sitting in corporations, it's the owners who have to declare the money on their 2017 tax returns.
In June, those hit by the tax were given a temporary reprieve — more time to file their tax returns and to make their first payments to the IRS.
Some of those advisers have been telling their clients to take money out of their corporations. While doing that would trigger a Canadian tax hit, under the Canada-U.S. tax treaty, tax payments made to one country are generally deductible in the other.
However, under the proposed regulations, the U.S. government plans to only allow a fraction of that deduction.
Experts say that may force many of those affected to take more money than they planned out of their companies and pay more in Canadian tax in order to mitigate the U.S. repatriation tax.
"The result of the guidance is that the amount that they're going to have to take out to avoid the double tax has increased significantly, and that is going to make this more expensive," said Reed.
Nightingale said many of his clients are going to have to take twice as much out of their Canadian corporations than they had planned on to avoid the transition tax.
"You have to pay out a whole lot of dividends from your corporation to generate Canadian tax so that you can claim a foreign tax credit in the U.S."
For Canada's federal government, that could result in a temporary tax windfall, Nightingale said.
"For the government of Canada, it's great ... It's actually going to bump Canadian federal and provincial revenues."
Tax lawyers and accountants say many of their clients — particularly those with dual citizenship and few, if any, ties to the U.S. — are already angry at the repatriation tax and the proposed regulations aren't going to make it any better.
"The guidance is going to make people even angrier and I think that's completely justifiable," said Reed.
"There is a treaty between the two countries and the point of that treaty is to make sure you don't pay tax twice on the same income ... this is a risk here and the guidance has made that worse."
Reed and Richardson said they believe the proposed regulations may violate the Canada-U.S. tax treaty.
"Is it a violation of the tax treaty itself for the United States to not allow the full amount of tax paid on a dividend in Canada to be used as a tax credit against the transition tax?" said Richardson. "I think it may very well be."
Nightingale is less convinced.
Canada's federal Department of Finance is still analyzing the potential impact of the tax and won't say whether the proposed regulations could violate the tax treaty.
"There are a number of tax changes underway in the United States," said department spokesman Jack Aubry. "The overall impact on U.S. citizens resident in Canada will depend on their personal situations.
"We recognize that certain U.S. tax changes are causing difficulties for U.S. citizens resident in Canada. The Department of Finance is conducting detailed analytical work to consider the impact of (the) U.S. tax reform."
Getting out of paying the repatriation tax by renouncing U.S. citizenship also has gotten harder.
Those
hit by the tax can elect to pay it over eight years — but the new
guidance says those who renounce their U.S. citizenship have to pay
it immediately.
Richardson said some people may have to keep their U.S. citizenship because they can't afford to pay the entire repatriation tax at once.
"It actually makes it impossible to renounce U.S. citizenship, turning U.S. citizenship into a sort of debtors prison," he said.
Richardson said the tax has fuelled efforts to lobby for a change in the way U.S. expats are taxed. The American Chamber of Commerce in Canada is organizing a talk in Toronto Thursday with Solomon Yue, CEO of Republicans Overseas, to discuss plans for a bill to tax Americans based on where they live rather than on their citizenship.
· CBC News · Posted: Aug 14, 2018 4:00 AM ET
Canadian
Finance Minister Bill Morneau says the government has raised the issue
of the repatriation tax with the U.S. government. (Chris Wattie/Reuters)
The Canadian government is talking to the U.S. government about the impact a retroactive tax signed into law by U.S. President Donald Trump is having north of the border, Finance Minister Bill Morneau revealed Monday.
Speaking to reporters in Windsor, Ontario, Morneau said he is aware that some of the U.S. government's tax changes affect Canadian residents with U.S. or dual citizenship.
But, he added: "It is, at the end of the day, going to be up to them to manage their own tax code."
U.S.
President Donald Trump displays the $1.5-trillion tax overhaul package
he signed in December. Among the measures in the tax reform package was a
one-time retroactive repatriation tax that is hitting thousands of
Canadian residents. (Evan Vucci/Associated Press)
Government
officials did not provide any further details such as who has been
speaking with the Americans, when and how many times.
"Finance officials have and will continue to engage with their U.S. counterparts to ensure they are aware of the negative impact on U.S. citizens abroad," Morneau's press secretary, Pierre-Olivier Herbert, said.
Morneau's comments mark the first time the government has indicated it is taking action regarding the tax rather than just studying it.
The
comments came as CBC News revealed Monday that thousands of Canadian
residents affected by the retroactive tax have been dealt a second blow:
proposed new rules unveiled a few days ago risk increasing the tax hit
for those affected.
In December, Trump signed a sweeping tax reform bill into law that included the Repatriation Tax, also known as the Transition Tax. It was designed to get big American multinational companies like Apple and Microsoft to stop parking billions of dollars in foreign subsidiaries. However, it's also hitting thousands of Canadian residents with U.S. or dual citizenship and a company incorporated in Canada.
Many Canadian residents, particularly those who have used their small corporations to save for their retirements, are facing tax bills amounting to hundreds of thousands of dollars on all of the retained earnings in their corporations going back to 1986. Some bills run into the millions.
While
the tax is being levied on money sitting in corporations, it is the
owners who have to declare the money on their 2017 tax return.
In June, those hit by the tax were given a temporary reprieve — more time to file their tax returns and to make the first payment to the U.S. Internal Revenue Service.
Tax lawyers and accountants have been grappling with the new tax, trying to find the best way to help their clients.
One strategy was for those affected to take money out of their corporations. While the move would trigger a Canadian tax hit, under the Canada-U.S. tax treaty, tax payments made to one country are generally deductible in the other.
However, under the proposed regulations, the U.S. government plans to only allow a fraction of that usual deduction.
Experts say that may force many of those affected to take more money than they planned out of their companies, and pay more Canadian tax in order to mitigate the U.S. repatriation tax.
Vancouver residents Suzanne and Ted Herman are facing a six-figure tax bill as a result of Trump's tax reform. (CBC)
Some experts say the new rules may violate the Canada-U.S. tax treaty, which is designed to prevent double taxation.
Asked whether the new rules contravene the Canada-U.S. tax treaty, Morneau didn't directly respond.
Earlier, Morneau said the Canadian government has been studying the U.S. tax reform package.
"We have been looking at the changes that the United States have made broadly in taxation, carefully considering how it is impacting, in particular, businesses across the country," he said.
"As you probably know, businesses have an investment environment where they can consider different options. So we're making sure that we understand the implications of those changes."
Elizabeth Thompson can be reached at elizabeth.thompson@cbc.ca
Newly proposed regulations issued by the U.S. Treasury Department and the Internal Revenue Service threaten to increase their tax hit.
"You have to almost empty out your company and pay a lot of Canadian tax to avoid the U.S. tax," said Kevyn Nightingale, a partner with the accounting firm MNP.
A 'Transition Tax' introduced by the Trump administration was intended to discourage U.S. multinationals from leaving vast sums in foreign subsidiaries. But the tax is also hitting Canadians with U.S. or dual citizenship who have companies incorporated in Canada.
While many of those affected had hoped to use a longstanding U.S. tax deduction to take some of the sting out of their tax bills, the proposed regulations — contained in a guidance document from Treasury and the IRS issued last week — will allow only a portion of that deduction.
Some experts say the proposed regulations may also violate a Canada-U.S. tax treaty which is supposed to prevent double taxation.
'A nightmare'
"My answer is likely yes — that the IRS guidance does violate the tax treaty," said Max Reed, a Vancouver-based cross-border tax lawyer with SKL Tax.
The new, 249-page guidance document is the latest twist in a complicated tale that some tax experts have described as a "nightmare."
In December, Trump signed a sweeping tax reform bill into law. It included the Transition Tax, also known as the Repatriation Tax, which was meant to get big American multinational companies like Apple and Microsoft to stop parking billions of dollars in foreign subsidiaries.
As a result, many Canadian residents with U.S. or dual citizenship — particularly those who have used their small corporations to save for their retirements — are facing tax bills amounting to hundreds of thousands of dollars on all of the retained earnings in their corporations going back to 1986. Some bills run into the millions.
While the tax is being levied on money sitting in corporations, it's the owners who have to declare the money on their 2017 tax returns.
In June, those hit by the tax were given a temporary reprieve — more time to file their tax returns and to make their first payments to the IRS.
It actually makes it impossible to renounce U.S. citizenship, turning (it) into a sort of debtors prison.- Lawyer John Richardson on new U.S. tax rules for overseas corporationsTax lawyers and accountants have been grappling with the new tax, trying to find the best way to help their clients.
Some of those advisers have been telling their clients to take money out of their corporations. While doing that would trigger a Canadian tax hit, under the Canada-U.S. tax treaty, tax payments made to one country are generally deductible in the other.
However, under the proposed regulations, the U.S. government plans to only allow a fraction of that deduction.
Experts say that may force many of those affected to take more money than they planned out of their companies and pay more in Canadian tax in order to mitigate the U.S. repatriation tax.
"The result of the guidance is that the amount that they're going to have to take out to avoid the double tax has increased significantly, and that is going to make this more expensive," said Reed.
Nightingale said many of his clients are going to have to take twice as much out of their Canadian corporations than they had planned on to avoid the transition tax.
"You have to pay out a whole lot of dividends from your corporation to generate Canadian tax so that you can claim a foreign tax credit in the U.S."
A windfall for Ottawa?
For Canada's federal government, that could result in a temporary tax windfall, Nightingale said.
"For the government of Canada, it's great ... It's actually going to bump Canadian federal and provincial revenues."
Tax lawyers and accountants say many of their clients — particularly those with dual citizenship and few, if any, ties to the U.S. — are already angry at the repatriation tax and the proposed regulations aren't going to make it any better.
"The guidance is going to make people even angrier and I think that's completely justifiable," said Reed.
"There is a treaty between the two countries and the point of that treaty is to make sure you don't pay tax twice on the same income ... this is a risk here and the guidance has made that worse."
Reed and Richardson said they believe the proposed regulations may violate the Canada-U.S. tax treaty.
"Is it a violation of the tax treaty itself for the United States to not allow the full amount of tax paid on a dividend in Canada to be used as a tax credit against the transition tax?" said Richardson. "I think it may very well be."
Canada's federal Department of Finance is still analyzing the potential impact of the tax and won't say whether the proposed regulations could violate the tax treaty.
"There are a number of tax changes underway in the United States," said department spokesman Jack Aubry. "The overall impact on U.S. citizens resident in Canada will depend on their personal situations.
"We recognize that certain U.S. tax changes are causing difficulties for U.S. citizens resident in Canada. The Department of Finance is conducting detailed analytical work to consider the impact of (the) U.S. tax reform."
Getting out of paying the repatriation tax by renouncing U.S. citizenship also has gotten harder.
Richardson said some people may have to keep their U.S. citizenship because they can't afford to pay the entire repatriation tax at once.
"It actually makes it impossible to renounce U.S. citizenship, turning U.S. citizenship into a sort of debtors prison," he said.
Richardson said the tax has fuelled efforts to lobby for a change in the way U.S. expats are taxed. The American Chamber of Commerce in Canada is organizing a talk in Toronto Thursday with Solomon Yue, CEO of Republicans Overseas, to discuss plans for a bill to tax Americans based on where they live rather than on their citizenship.
Canada talking with U.S. about Trump tax: Morneau
Retroactive repatriation tax hitting thousands of Canadian residents
· CBC News · Posted: Aug 14, 2018 4:00 AM ET
The Canadian government is talking to the U.S. government about the impact a retroactive tax signed into law by U.S. President Donald Trump is having north of the border, Finance Minister Bill Morneau revealed Monday.
Speaking to reporters in Windsor, Ontario, Morneau said he is aware that some of the U.S. government's tax changes affect Canadian residents with U.S. or dual citizenship.
It is, at the end of the day, going to be up to them to manage their own tax code.- Finance Minister Bill Morneau"We're continuing to consult with Americans to make sure that we fully represent the challenges that these changes have made for Americans or dual citizens living in Canada," Morneau said. "That's an ongoing process. We certainly hope that we can make progress."
But, he added: "It is, at the end of the day, going to be up to them to manage their own tax code."
"Finance officials have and will continue to engage with their U.S. counterparts to ensure they are aware of the negative impact on U.S. citizens abroad," Morneau's press secretary, Pierre-Olivier Herbert, said.
Morneau's comments mark the first time the government has indicated it is taking action regarding the tax rather than just studying it.
In December, Trump signed a sweeping tax reform bill into law that included the Repatriation Tax, also known as the Transition Tax. It was designed to get big American multinational companies like Apple and Microsoft to stop parking billions of dollars in foreign subsidiaries. However, it's also hitting thousands of Canadian residents with U.S. or dual citizenship and a company incorporated in Canada.
Many Canadian residents, particularly those who have used their small corporations to save for their retirements, are facing tax bills amounting to hundreds of thousands of dollars on all of the retained earnings in their corporations going back to 1986. Some bills run into the millions.
Politics News
Morneau says Ottawa is talking to Washington on Trump tax
00:00
01:05
Finance Minister Bill Morneau visited Windsor on Monday 1:05
In June, those hit by the tax were given a temporary reprieve — more time to file their tax returns and to make the first payment to the U.S. Internal Revenue Service.
Tax lawyers and accountants have been grappling with the new tax, trying to find the best way to help their clients.
One strategy was for those affected to take money out of their corporations. While the move would trigger a Canadian tax hit, under the Canada-U.S. tax treaty, tax payments made to one country are generally deductible in the other.
However, under the proposed regulations, the U.S. government plans to only allow a fraction of that usual deduction.
Experts say that may force many of those affected to take more money than they planned out of their companies, and pay more Canadian tax in order to mitigate the U.S. repatriation tax.
Asked whether the new rules contravene the Canada-U.S. tax treaty, Morneau didn't directly respond.
Earlier, Morneau said the Canadian government has been studying the U.S. tax reform package.
"We have been looking at the changes that the United States have made broadly in taxation, carefully considering how it is impacting, in particular, businesses across the country," he said.
"As you probably know, businesses have an investment environment where they can consider different options. So we're making sure that we understand the implications of those changes."
Elizabeth Thompson can be reached at elizabeth.thompson@cbc.ca
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