Attribution Rules on Relationship Breakdown

May 23, 2024 |Charles W. Cullen III
If there's a breakdown in your relationship, you and your spouse may need to determine how to divide up your assets. This article discusses the situations where attribution does and does not continue to apply even after a relationship breakdown. For more...
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Planning Considerations for Corporations Selling Securities Prior to June 25, 2024

May 16, 2024 |Charles W. Cullen III
Canada's recently unveiled 2024 federal budget proposes to increase the capital gains inclusion rate to 66.67% from 50%. This article focuses on the impacts this may have on your corporation and whether you should consider selling securities before the...
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Planning Considerations for Medical Professional Corporations Selling Securities Prior to June 25, 2024

May 09, 2024 |Charles W. Cullen III
Canada's recently unveiled 2024 federal budget proposes to increase the capital gains inclusion rate to 66.67% from 50%. This article focuses on the impacts this may have on your medical professional corporation (MPC) and whether you should consider selling...
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FHSA Quick Tips

May 02, 2024 |Charles W. Cullen III
With spring normally being a busy time for buyers and sellers of homes, we thought it would be good to review Canada's newest registered account, the First Home Savings Account (FHSA). For information on how they work, please click below. To see how it...
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2024 Federal Budget - Planning for the Proposed Increase to the Capital Gains Inclusion Rate

April 25, 2024 |Charles W. Cullen III
The recently released federal budget proposes to increase the capital gains inclusion rate to 66.67% from 50%. This change is scheduled to come into effect on June 25th, 2024. Although there are still lots of unanswered questions, there are already some...
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Canadian Non-Resident Withholding Tax

April 10, 2024 |Charles W. Cullen III
For non-residents of Canada that have Canadian sourced income, it is important to understanding the potential withholding tax implications. As always, for a more detailed discussion, please reach out. Click Here
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Passive Foreign Investment Company (PFIC) Rules

April 09, 2024 |Charles W. Cullen III
For U.S. persons living in Canada, knowing the Passive Foreign Investment Company (PFIC) rules is extremely important. Examples of holdings that typically fall under these rules are Canadian mutual funds and exchange trade funds. For more information...
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Canadian Owners Renting or Selling U.S. Real Estate

April 04, 2024 |Charles W. Cullen III
Looking to escape the long and cold winter, many Canadians are now called "snowbirds" - flocking to popular warm-climate destinations in the U.S. However, owners of these properties should be aware of the potential U.S. tax issues they may face. For more...
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Alter Ego and Joint Partner Trusts for U.S. Persons

March 28, 2024 |Charles W. Cullen III
Trusts are complicated. They becoming even more complicated when a U.S. person living in Canada opens a Alter Ego Trust or a Joint Partner Trust as they must be aware of both the Canadian and U.S. tax and estate planning implications. For more information...
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Determining Your Tax Residency Status in Canada

March 21, 2024 |Charles W. Cullen III
In Canada, unlike the U.S., the income tax system is based on Canadian residency status. This articles discusses some of the factors that are considered when determining your residency status for Canadian tax purposes and some potential implications....
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