We are advisors

to our clients as they work to cope with a complex, rapidly changing world. It’s a long term commitment.
Accountants & Advisors for a Complex World™

At home in the USA

Many of our clients are affected by the need for tax compliance in both Canada and the USA. They have come to trust the support they receive from our dedicated International Tax team. Headed by Joseph E. Sardella, CA, CPA, the team provides comprehensive corporate and individual tax advice and service to manage the complexities of international filings, ensuring full compliance and no surprises.
 

Corporate
Many of our private and public clients view expansion into the US market as a natural and inevitable part in the evolution of their business life cycle, enabling them to tap into new sources of capital and position themselves for success in new and emerging markets beyond America. 

Although business decisions should not be driven primarily for tax advantages, neglecting to integrate tax planning into overall strategy is perilous and the costs can be high.

Tax legislation is changing at a rapid pace and is intended to striking a balance between closing tax loopholes and providing tax incentives. The shelf life for tax planning ideas is becoming increasingly short.

Globalization has resulted in greater tax transparency and effective tax strategy has developed a defensive component.
 

Individual
The USA is one of a few countries that taxes based on citizenship regardless of physical residence and new US tax legislation is in place that targets US citizens who have not been filing US tax returns and non-tax information returns.

Unlike previous years, the US is taking a hard line on catching non-tax filers. The IRS has been granted the power to impose significant penalties ranging from $10,000 to $500,000 - including jail time - for delinquent filers.

US tax rules also extend beyond US citizens to those foreign persons carrying on business in the US or holding US investments in real estate or stock of US corporations. Many foreign persons are shocked to discover that they are subject to US gift tax on certain real estate transactions and also subject to US death taxes on US property.

In previous years such “foot fouls” were rectified by voluntary filings showing good faith in complying with the US tax rules. Today, ignorance of US tax rules is no excuse.

 

Of further interest:
We invite you to read 3 articles from the American Institute of Certified Public Accountants, each co-authored by Joseph Sardella.

COMMENTS ON FOREIGN TRUST REPORTING ISSUES.Download PDF

COMMENTS ON CFC LOOK-THROUGH RULE GUIDANCE.Download PDF

COMMENTS ON NOTICE 2005-74 REGARDING THE EFFECT OF CERTAIN EXCHANGES ON GAIN RECOGNITION AGREEMENTS (GRAs) UNDER SECTION 367(a).Download PDF