Kevyn Nightingale, "American Professionals in Canada", Canadian Tax Journal, (2017) 65:4, 893-937

No additional U.S. tax where income earned directly by U.S. citizen/Cdn resident (p. 898)

…US taxable income will typically be lower than...

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use of gift of discretionary shares to address PFIC issues

Although there may be significant advantages for a Canadian-resident professional to incorporate, challenges arise where the professional (or a...

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