May 2017
Multistate Foreign Corporation State Income Taxation – Factor Presence Nexus
Lily Lo, CPA (Illinois, USA), is a senior manager of tax services in the Edmonton office of Collins Barrow
Is it possible that a foreign corporation that has no physical presence in a state could be required to pay state income taxes resulting from business/sales within that state? The answer is yes. This surprises many foreign corporations, who find that additional state income taxes may result by them simply making sales in a particular state.
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Final U.S. Rules for Related-Party Debt
Jim McEvoy is a partner, U.S. tax, in the Calgary office of Collins Barrow
On October 13, 2016, the U.S. Treasury Department and the IRS issued final and temporary regulations under Internal Revenue Code Section 385. These regulations offer some relief to the provisions of the proposed regulations which were issued on April 4, 2016. For details of the proposed regulations, see Collins Barrow - U.S. Tax Alert, U.S. Proposes New Rules for Related-Party Debt.
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Collins Barrow periodically publishes U.S. Tax Alert for its clients and associates. It is designed to highlight and summarize the continually changing tax and business scene across Canada with respect to U.S. issues. While U.S. Tax Alert suggests general planning ideas, we recommend professional advice always be sought before taking specific planning steps.