Canada: Tax Liability For Directors – Resignation Exception

In a recent decision from the Tax Court of Canada in  Achim Bekesinski and Her Majesty the Queen  (” Bekesinski “), the taxpayer, as director of a corporation, was personally reassessed by the Minister of National Revenue (“Minister”) in the amount $477,546.08 for the corporation’s unremitted income tax, employer contributions, interest and penalties for its 2001 to 2003 tax years.  This type of Assessment is commonly called a director’s liability assessment.
Director was not liable for Corporation’s Tax […]

By |September 8th, 2014|

If I Had A Hammer – A Creative Method For Repatriating Offshore Corporate Profits

Overview
In this era of corporate inversions, there seems to be a lot of mud-slinging going around. Congress and the current Presidential administration would like to label large multi-national corporations as traitors. Somewhere along the line, the people in government seemed to miss the part about a corporation’s legal obligation to its shareholders. The Republican Party continues to clamor about the need to reduce the corporate tax rate, but it seems to me that most […]

By |August 27th, 2014|

Change To UK Tax Laws – Implications For Non-UK Domiciled Individuals

HM Revenue & Customs (HMRC), the UK’s tax authority, made an unexpected change to the tax regulations for non-UK domiciled individuals that they announced on 4 August 2014. The change relates to loans secured against overseas assets or monies – and will impact individuals and those using offshore trust / company structures.
Background
Income or capital gains from overseas assets are liable to taxation when brought into the UK. However, under a ‘concession’ in the tax […]

By |August 26th, 2014|