Fuller Landau team • June 13, 2025Foreign corporations earning effectively connected income (“ECI”, essentially trade or business income from US sources) are required to timely file an annual Foreign Corporation Tax Return (Form 1120-F) reporting US income, deductions, and credits. However, failure to file on time can result in not only penalties and interest, but also more dra ... Read more
Jeffrey Brown
• February 07, 2022In 2021, the Multistate Tax Commission (MTC) updated its Statement of Information Concerning Practices of the Multistate Tax Commission and Supporting States Under P.L. 86-272 with guidance addressing online activities. For more than 50 years, P.L. 86-272 has limited a state’s ability to impose income tax on an out-of-state vendor that does nothi ... Read more
Jeffrey Brown • June 21, 2021Fuller Landau welcomes President Biden’s tax proposal to vest Internal Revenue Service (IRS) with authority to regulate all paid preparers of US tax returns and establish mandatory minimum competency standards. IRS’ current authority extends only to licensed attorneys, certified public accountants (CPA), enrolled agents (EA) and actuaries. Atto ... Read more
Jeffrey Brown
• December 20, 2018Many Canadian companies, and their tax advisors, operate under the mistaken belief that the US Canada Tax Treaty protects them from ALL cross-border taxation in the US. This couldn’t be farther from the truth. The Treaty protects a Canadian company from US federal income taxation on its US trade or business income so long as ... Read more
Jeffrey Brown
• November 19, 2018The United States considers US Green Card holders to be US residents for tax purposes. Green card holders file tax returns and pay US tax on their worldwide income as do US citizens, even if they live in Canada. Canada generally considers those who permanently reside in Canada to be Canadian residents for Canadian tax ... Read more
Foreign corporations earning effectively connected income (“ECI”, essentially trade or business income from US sources) are required to timely file an annual Foreign Corporation Tax Return (Form 1120-F) reporting US income, deductions, and credits. However, failure to file on time can result in not only penalties and interest, but also more dra ... Read more