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BOUTIQUE
US TAX FIRM

Specializing in US Taxation

Consulting & Compliance Corporations & Individuals

PRACTICE AREAS

PRACTICE AREAS

US TAX COMPLIANCE

US TAX ADVISORY

US TAX DISPUTES & ADVOCACY

Compliance Forms for Corporations, Partnerships and Individuals, including but not limited to, the following:

Form 1120, U.S. Corporation Income Tax Return

Form 5472, Information Return of a 25% Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business 

Form 5471, Information Return of U.S. Persons With Respect To Certain Foreign Corporations 

Form 1120F & Form 8833, U.S. Income Tax Return of a Foreign Corporation (Treaty Based) 

Form 1120F (Branch), U.S. Income Tax Return of a Foreign Corporation 

Form 1065, U.S. Return of Partnership Income 

Sch K-1, K-2 & K-3, Partner Slips 

Form 8805 & 8804, Return for Partnership Withholding Tax 

State Forms, Various 

Form 1042, 1042T, & 1042S, Withholding Tax Return for U.S. Source Income of Foreign Persons 

Form W-8BEN-E & W-9, Identification Purpose forms

Form 1099-NEC, Nonemployee Compensation 

Form 8288 & 8288-A, U.S. Withholding Tax Return for Certain Dispositions by Foreign Persons 

Form 8288-B, Application for Withholding Certificate for Dispositions by Foreign Persons of U.S. Real Property Interests 

Form 1040U.S. Individual Income Tax Return

Form 1040NR, U.S. Nonresident Alien Income Tax Return

FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR) 

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US Taxation

  • In general, all domestic US corporations (including corporations in bankruptcy) must file an income tax return whether or not they have taxable income.

  • Canadian individuals and corporations are generally subject to US tax on:​

    • FIRPTA

    • ECI

    • FDAP

FIRPTA

FIRPTA “Foreign Investment in Real Property Tax Act” gains from the sale of US real property interests are treated as effectively connected income

  • FIRPTA is a withholding tax on the disposition of US real property by a foreign person.

  • The purchaser must withhold and remit tax of up to 15% of the gross selling price to the Internal Revenue Service (“IRS”) on behalf of the seller unless certain exemption apply.

ECI

ECI “Effectively Connected Income” when a foreign person engages in a trade or business in the US, all income from sources within the US connected with the conduct of that trade or business 

  • Canada-US Income Tax Convention (the “Treaty”)

    • Only taxable if trade or business is conducted through a permanent establishment (“PE”) in the US

FDAP

FDAP “fixed, determinable, annual, and periodical” income that is not effectively connected to the United States  

  • FDAP income captures a board range of gross income: Interest, Dividends, Rents, Royalties

  • Flat tax of 30% on “fixed or determinable annual or periodical gains, profits and income” unless the Treaty applies

If you’d like more information about our services, get in touch today.

ATTORNEYS
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SANDY JIANG

CPA, CPA (Delaware), CICPA Juris Master

Shan Jiang CPA Professional Corporation

Partner, US Tax Services

Sandy brings years of experience in practicing US Tax. She has practiced at national firms, in the mid-size accounting arena as well as local practices. Sandy specializes in Canada-US cross-border tax matters and in-bound US tax services for public and privately held corporations.​

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Sandy is passionate about making a positive impact for their clients. The US tax landscape has been changing at an unprecedented pace with increased complexities. Their desire is to help clients navigate these waters and ease the burden.

CONTACT

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