News & Analysis as of

Canada Foreign Tax Credits

Cozen O'Connor

What Canadian High Net Worth Families Should Know About the U.S. One Big Beautiful Bill

Cozen O'Connor on

The United States recently passed tax legislation called the One Big Beautiful Bill Act (OBBBA), a follow-up to the 2017 Trump tax cuts. While the bill is American, many Canadian families with cross-border ties, including...more

Fenwick & West LLP

Bruyea v. United States - Latest Foreign Tax Credit Case on the NIIT Sheds Important Light on Treaty Double Tax Articles

Fenwick & West LLP on

Bruyea v. United States (Ct. Claims Dec. 5, 2024), is the latest in a series of cases concerning whether a U.S. double tax treaty, in this case Canada's, allows a foreign tax credit for Canadian income taxes against the 3.8%...more

Cole Schotz

Canadians who own US Real Estate – US Estate Tax Implications

Cole Schotz on

Many Canadians own US-situs real estate, whether it is in New York, Florida, California or elsewhere in the US. It is often a surprise (or a “trap for the unwary”) to Canadian clients (or for that matter, any non-US client)...more

Snell & Wilmer

Canadians Who Invested in U.S. LLPs and LLLPs Need to Rethink Their Choice of Entity

Snell & Wilmer on

Historically, Canadian investors in U.S. partnerships benefitted from an extremely efficient income tax structure – i.e., a single level of tax, credit against Canadian taxes for taxes paid in the U.S., and an ability to...more

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