Resources & Articles

Cross-Border Tax


Foreign Entities Sharing COVID-19 Assistance via Transfer PricingAugust 5th, 2020

Transfer Pricing Memorandum (TPM)-17 is meant to prevent Canadian government assistance from being used to benefit a party outside of Canada which would not have...
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US Taxation and Canadian SnowbirdsMay 28th, 2020

We often get asked “How much time can I spend in the United States without tax consequence?” and “What are the tax rules for owning...
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U.S. EXPATRIATES: New Relief ProceduresMay 21st, 2020

On September 6, 2019, the IRS announced Relief Procedures for Certain Former Citizens, a new process to facilitate eligible individuals in becoming compliant with their...
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Meet the International Tax TeamApril 22nd, 2020

Meet our team of International Tax Professionals. Whether it’s an international move or a business opening across borders, they can help you with tax planning...
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We Can Help you with International Tax Planning and ComplianceFebruary 27th, 2020

At DJB, our focus is to understand our clients’ needs and develop a customized plan to ensure these needs are met. Whether it’s an international...
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The Canadian Tax Implications of Cross-border Debt FinancingFebruary 5th, 2020

Debt financing that is used in cross-border transactions can result in adverse tax consequences if Canadian tax rules are not adhered to. In this article...
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Global Intangible Low-Taxed Income (GILTI)January 29th, 2020

The Global Intangible Low-Taxed Income (GILTI) regulation was enacted in Section 951A of the U.S. Internal Revenue Code by the 2017 U.S. Tax Cuts and...
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U.S. Federal Tax Consequences for Canadian Businesses with US OperationsNovember 21st, 2019

Background Canadian businesses continue to extend their reach into the U.S. for numerous reasons; some of which include proximity, lower corporate tax rates as a...
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T1135 Reporting of Foreign Property UpdateAugust 14th, 2019

The CRA’s Voluntary Disclosure Program gives taxpayers a second chance to correct unintentional errors or omissions in income tax filings. Taxpayers can seek to mitigate...
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US TAX ISSUES FOR US CITIZENS AND GREENCARD HOLDERS LIVING IN CANADAMay 23rd, 2019

Filing Requirement The liability for US tax is based on both citizenship and residence. Therefore, as a US citizen you must file annual US income...
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