It’s Not 6 Months Less a Day

There is a misunderstanding that the US will only consider you to be resident for tax purposes (assuming that you are not a US citizen) if you spend more than 6 months a year in the country. It's not that simple. The US looks at days of presence to establish residence. It is a three-year test where you add all of the days in the current year, plus 1/3 of the days in the immediately preceding...

The Unanimous Shareholder Agreement – A Primer

What is a Unanimous Shareholder's Agreement? A Unanimous Shareholder's Agreement (“USA”) is distinct from the company's constitution or its articles. Without a USA, the Company would be controlled solely and exclusively by the exercise of shareholder or directorship rights through its constitution and the business corporations legislation of its home jurisdiction, which are generally...

US Property as a Non-Resident

Normally, an individual will complete a Will and other estate planning documents where (s)he is "domiciled," which is a legal concept similar, but not identical, to "residence." What happens when you own property outside of your home state or province, though? There are several options that are available to you to address this issue. You could own the property through a corporation or other type...

Withholding v. Tax Paid

Withholding is best thought of as an estimate of tax. So, when you have income from some source, some amount is withheld ofr your future tax obligation. The amount withheld for tax, though, may not be the actual amount of tax that you are required to pay. For example, in the case of the withdrawal of Canadian RRSPs by a US resident, if you withdraw them in a lump sum, the tax treaty indicates...

One of a Kind Personalized Attention

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The Privacy, Data Protection and Cybersecurity

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Simplicity out of Chaos

You have a unique problem.  We want to offer a unique solution.  There is a lot of white noise and you don't know how to sort through it.  "How do I start a business in the US? How many days can I spend in each country? If I have property in Arizona, how do I leave it to my kids in Canada?"  As a lawyer licensed in both Arizona and Alberta, Canada, I have the unique experience and...