Brunton's U.S. Taxletter for Canadians-Winter 1996

Representing Canadian Businesses and Professionals for over 15 years

Search this site.

Covering U.S. Tax, Immigration, and Financial Matters Affecting Canadian Non-Resident Aliens Of The United States*
WINTER 1996/Vol. 12, No. 1

The first non-immigration question you or your Canadian employee may ask is "how will my taxes change when I work in the U.S.?"

Tax considerations can often make or break a transfer to the U.S. These tax equalization issues can come squarely within the responsibility of the HR Manager. (See a complete checklist of all HR issues relating to Canada to U.S. employee transfers.)

Richard Brunton has answered these tax questions for over twenty years. His newsletter is the best source of current information for your relocating employees.

We are pleased (and honored) to share our Web site with Mr. Brunton.

We urge you to take out a regular subscription to the newsletter for yourself. Consider securing a subscription for each of your transferring employees. Large tax savings can result.

See the home page for links to other issues of this Taxletter.


Return to the top of this Table of Contents

About The Author And How To Subscribe

Photograph of Richard Brunton, Author of BRUNTON'S U.S. TAXLETTER

Richard Brunton holds a Masters degree in Taxation/Accounting, in which his primary interest has been international taxation. He has been a resident of Florida for the past 22 years.

Mr. Brunton's firm assists these Canadians who:

His firm also assists U.S. citizens or U.S. Green Card holders, living in Canada.

Brunton's U.S. Taxletter for Canadians is published three times per year by Tax Reports Inc. It is available for US $30 per year. Please contact Mr. Brunton's office if you wish to subscribe:

Richard Brunton, CPA
4710 NW Boca Raton Blvd. Suite 101
Boca Raton, Florida
Voice: 407.241.9991
FAX: 407.241.6332

Return to the Table of Contents at the top of this page

Important Deadline for New Treaty Estate Benefit


If a Canadian becomes deceased while owning U.S. property exceeding US $60,000 the executor of the estate generally must file a U.S. estate tax return within nine months of the date of death, unless an extention is obtained. The nine month filing deadline is often missed, perhaps because the surviving spouse is not aware of the U.S. filing requirement. Until now, there have been at least two potentially unfortunate results of the late filing:

  1. The IRS will assess penalties and interest for late filing if there is tax due.
  2. The estate is prevented from claiming a tax deferral via the use of a "qualified domestic trust" if the relevant election is not made by a special deadline (generally no more than one year after the due date for the return, excluding extentions).

We now have a critical new deadline. Readers are aware there is a new marital tax credit provided under the new tax treaty Protocol (please see the Fall, 1995 issue of the Taxletter). This marital tax credit can be vital because it potentially doubles the federal tax credits for many estates. However there is a deadline for making this marital credit claim, (including the appropriate election and waiver). The deadline is the same date for making the "qualified domestic trust" election described above.

In other words, if an individual died, say, December 1, 1995, and no extentions were obtained, the marital tax credit must be properly claimed by September 1, 1997, otherwise it appears this important tax credit may be forfeited. For individuals who died after November 10, 1988 and before November 9, 1995 it appears special rules apply.

Return to the Table of Contents at the top of this page

Revenue Canada Reviewing Single Purpose Company Rules

As a general rule, Revenue Canada may assess a taxable benefit to a Canadian shareholder of a Canadian company if the shareholder has personal use of the corporate property. However readers are aware Revenue Canada has issued "single purpose company" guidelines. Under these rules, Revenue Canada may not assess a shareholder benefit against you if you own a U.S. residence through a Canadian company that is operated in accordance with the guidelines. (Please consult your Canadian tax advisor for details). Revenue Canada issued the guidelines, at least in part, as a response to U.S. estate tax legislation, and to assist Canadians in owning a U.S. residence.

As a result of the new tax treaty Protocol which entered into effect November 9, 1995, Revenue Canada is reconsidering its policy. Since the new Protocol is intended, in part, to alleviate your exposure to U.S. estate tax it is possible Revenue Canada will decide to amend the single purpose company guidelines.

Return to the Table of Contents at the top of this page

"Closer Connection" Time Again!

Every year at this time certain "snowbirds" must file a U.S. "closer connection" statement (if qualified). Otherwise they may be considered U.S. residents for U.S. income tax and possibly subject to U.S. tax on their worldwide income. As a broad generality, (with many exceptions) you would normally want to consider filing a closer connection statement if you spend between four months and six months annually in the United States. If, during the year, you had a green card (or had an application for adjustment of status pending) you are not qualified to file. Also, the filing does not apply to U.S. citizens.

The overall U.S. rules to determine your U.S. residency status can be complex - Figure 1 is a slightly adjusted copy of a decision tree printed in an IRS Publication. From Footnote 2 to Figure 1, you can see that even if you are considered a U.S. resident, you may have tax treaty protection. This may enable you to file your U.S. tax return as a nonresident, even though you meet the U.S. residency rules.

A blank closer connection statement can be obtained by calling the IRS at 1-800-829-3676. Ask for Form 8840. The deadline for filing your 1995 statement is June 15, 1996 (April 15, 1996 if you received wages subject to U.S. withholding).

Figure 1. Non-resident Alien or Resident Alien?

Start here to determine your status for 1995. Were you a lawful permanent resident of the United States (had a "green card") at any time during 1995?

If yes, you are a resident alien for U.S. tax purposes¹·² If no, were you physically present in the United States on at least 31 days during 1995?

If no, you are a non-resident alien for U.S. tax purposes.

If yes, were you physically present in the United States on at least 183 days during the 3-year period consisting of 1993, 1994, and 1995, counting all days of presence in 1995, 1/3 the days of presence in 1994, and 1/6 the days of presence in 1993³?

If no, you are a non-resident alien for U.S. tax purposes.

If yes, do you still meet the 183-day test of the preceding question if you disregard days for which you were an "exempt individual"?

If no, you are a non-resident alien for U.S. tax purposes. If yes, were you physically present in the United States on at least 183 days during 1995?

If yes, you are a resident alien for U.S. tax purposes.¹·²

If no, do you qualify for, and did you file, a valid "closer connection" statement for 1995?

If yes, you are a non-resident alien for U.S. tax purposes. If no, you are a resident alien for U.S. tax purposes.¹·²

  1. If this is your first or last year of residency, you may have a dual status for the year.
  2. In some circumstances you may still be considered a non-resident alien under an income tax treaty between the U.S. and your country.
  3. Do not count the days you were unable to leave the United States because of a medical condition that arose while you were in the United States.

Return to the Table of Contents at the top of this page

New Cross-Border Pension Withholding Rules

We previously mentioned the new rules, beginning January 1, 1996, which affect Canadians receiving U.S. social security payments or U.S. residents receiving Canada Pension Plan (CPP/QPP) or Old Age Security (OAS) payments. As of January 1st, these payments are taxed only in the country from which they are paid and will not be taxable in the country of residence of the recipient.

For example, Canadians resident in the United States who receive CPP/QPP or OAS will automatically have 25% Canadian tax withheld. No further U.S. tax will be payable. Some of these individuals will be able to file Revenue Canada Form NR5 and have this withholding reduced and/or file a Canadian tax return ("217 return") to obtain a reduction and/or a refund.

Canadians resident in Canada who receive U.S. social security payments will have 25.5% U.S. tax withheld but no further Canadian tax will apply. This odd amount (25.5%) is based on the regular U.S. withholding rate of 30% multiplied by the taxable portion of the payment (85%).

Return to the Table of Contents at the top of this page

Procedure For Claiming Protocol Estate Benefits

The IRS has issued informal guidance on the procedure you can use on the U.S. estate tax Form (IRS Form 706NA) to claim certain estate tax benefits under the new tax treaty Protocol which entered into force November 9, 1995. The guidance covers the proportionate unified tax credit, the marital tax credit and the limited exemption for estates not exceeding US $1.2 million.

The proportionate credit should be computed and described on a separate statement and then entered on Page 1, line 7, of Form 706NA, (the line normally used for the "standard" unified credit).

The marital credit should be computed and described on a separate attached statement and then entered on Page 1, line 11. On line 11 the existing words "Credit for Federal gift taxes etc." should be deleted and the words " marital credit" should be entered to the right of your dollar entry.

If you are claiming the limited exemption for estates not exceeding US $1.2 million the exempt assets can be listed on Schedule A without their values being included, or you can enter them as a memorandum item on a statement attached to the return. However, if you are claiming this exemption it appears the IRS will want you to include the value of the exempt assets on line 2, of Schedule B (property outside the United States) and to document the amounts. This will result in the exempt assets becoming part of the "denominator", but not the "numerator", for the computation of the proportionate unified tax credit. Legislation has been proposed to confirm this treatment.

If you are filing for a refund of tax previously paid on an original estate tax return you should include the words "Amended Return" in red at the top of Page 1. On Page 1, line 18, you should enter the amount of tax and penalties previously paid. The IRS has informally indicated it may take a minimum of six months to process refund applications.

Return to the Table of Contents at the top of this page

Florida Increases Corporate Penalty To $1,000

Subscribers are aware, a Canadian corporation must obtain "authorization to transact business" in Florida if the company rents out its Florida real estate, holds a mortgage in Florida, or otherwise transacts business in Florida. (Most other States have similar laws).

Until recently the Florida penalty was $500 per year for each year the company did not comply. However the penalty has now been increased to $1,000 for each year of noncompliance.

As we described in prior Taxletters, the State of Florida is reviewing Florida corporate income tax returns filed by Canadian companies to determine if the companies have obtained the necessary "authorization to transact business". The penalty of $1,000 will likely be levied for each year the tax return was filed if any required "authorization" was not obtained and the corporation does not have an adequate explanation.

It is possible Florida ultimately may start cross-checking sales tax reports on rental income filed by Realtors and property owners to determine if the corporate property owners have obtained the required "authorization". Please feel free to contact us for more information and details on how to comply.

Return to the Table of Contents at the top of this page

Renouncing U.S. Citizenship

Occasionally a U.S. citizen residing outside the United States who has no plans to return to live in the U.S. may decide that renouncing U.S. citizenship may be preferable to the continuing tax and other regulatory obligations to which he/she is subject as a U.S. citizen.

A U.S. citizen may voluntarily give up U.S. citizenship by performing one of the following acts, (called "expatriating acts"), with the intention of relinquishing U.S. nationality:

  1. Becoming naturalized in another country
  2. Formally declaring allegiance to another country
  3. Serving in a foreign army
  4. Serving in certain types of foreign Government employment,
  5. Making a formal renunciation of nationality before a U.S. diplomatic or consular officer in a foreign country,
  6. Making a formal renunciation of nationality in the United States during a time of war,
  7. Committing an act of treason.

If you wish to formally renounce U.S. citizenship, [item 5) above], you must execute an oath of renunciation before a consular officer. In this case your loss of citizenship is effective on the date the oath is executed.

In all other cases your loss of citizenship is effective on the date the expatriating act was committed, even though it may not be documented until a later date. The U.S. State Department will document loss of citizenship in such cases when you acknowledge to a consular officer that the expatriating act was taken with the requisite intent.

To officially document your loss of citizenship you can apply for a Certificate of Loss of Nationality (CLN). In all cases the consular officer will submit a CLN to the State Department in Washington for approval. Before issuing the CLN the State Department will review the file to confirm:

  1. You were a U.S. citizen
  2. An expatriating act was committed
  3. The act was undertaken voluntarily
  4. You had the intent of relinquishing citizenship when the expatriating act was committed.

If the expatriating act involved an action of a foreign Government (for example you were naturalized in a foreign country, or joined a foreign army) the CLN will not be issued until the State Department obtains confirmation from the foreign Government that the expatriating act occurred.

If a CLN is not issued because the State Department does not believe an expatriating act occurred (for example the requisite intent appears missing) the issue may be resolved through litigation. In this case the burden of proof is on the person to prove the loss occurred.

In some cases where a CLN may be improperly issued (for example - fraudulent documentation, or the requisite intent was lacking), the CLN may be revoked. The IRS can make a request that a CLN be revoked if it wishes to collect tax from an individual as a U.S. citizen and it believes a CLN was improperly issued.

Return to the Table of Contents at the top of this page

Green Card Holders In Canada Beware New Principal Residence Proposal!

The Canadian and U.S. tax rules on the sale of a principal residence are different. Canada may exempt you from tax on the profit, but the U.S. attaches conditions.

The U.S. has two separate provisions:

  1. You are able to defer (postpone) tax on part or all of your profit, depending upon whether you buy a new replacement principal residence with a certain value within a prescribed time period
  2. If you are 55 or older and used the property as a principal residence for three of the last five years you have a one-time exemption from tax on the first $125,000 of profit on a joint tax return ($62,500 if married filing separately).

. The difference between the Canadian and U.S. rules provides a potential tax trap for green card holders in Canada, and more trouble may be on the way. If you sell a Canadian residence for a profit and are exempt Canadian tax, there may still be U.S. tax payable if you do not meet the U.S. requirements for deferral or exemption mentioned above.

At the moment you may still qualify for the U.S. tax deferral described in 1) above if the replacement residence is located in Canada. However the U.S. Congress has proposed legislation that would eliminate the tax deferral unless the replacement residence is located in the United States. Hence if you have a green card you could sell a Canadian residence for a profit and have U.S. tax to pay even if you bought a replacement residence in Canada of greater value. (The one-time exclusion would not be changed under the proposal). We will keep you advised if the law is enacted.

Return to the Table of Contents at the top of this page

Ordering Rules For Estate Tax Credits

Several different estate tax credits may apply to an estate tax return. One of these tax credits - the credit for State death taxes, (e.g. Florida estate tax) actually creates an offsetting separate tax liability to the individual State in which the property in located. The amount of one tax credit may depend on the amount of tax remaining after another tax credit has been calculated. Hence we have "ordering rules" for the tax credits. The ordering rules guide us to the sequence in which they are computed.

Example: Assume Michael dies July 1, 1996 while owning the following worldwide property, all expressed in U.S. dollars:


U.S. residence in Florida

(result in most other states is similar)      150,000

Residence in Canada                           200,000

Other Canadian property, including cars,

RRSP's/RRIFs and Canadian investments         650,000	

Total                                      $1,000,000									

Except for the RRSP/RRIF, all property is owned jointly by Michael and his wife, Joan, and was purchased after 1988 with funds supplied solely by Michael. Joan has her own separate property. The RRSP/RRIF's were also purchased with funds provided solely by Michael. Michael made no prior U.S. taxable gifts and the U.S. residence was never rented out.

The U.S. federal and Florida estate tax for Michael's estate are computed as follows, ignoring potential deductions, and assuming he was not engaged in U.S. business and there are no other U.S. tax factors involved. The State tax computation would be similar if the property were located in many other States.

Taxable estate                   $150,000

U.S. federal estate

tax before tax credits      (1)    38,800

Unified tax credit          (2)    28,920

Balance of federal tax              9,880

Credit for Florida

tax (Florida tax payable)   (1)       400

Balance of federal tax              9,480

Marital tax credit           (3)    9,480

Balance owing -Federal tax              0

              -Florida (above)        400

Total estate tax payable              400

  1. Computed from tax rate schedule
  2. Since 15% of the worldwide property is located in the U.S., the tax credit is 15% of $192,800. (See the 1995 Fall issue of the Taxletter).
  3. Since all the U.S. property goes to the surviving spouse, the marital credit is equal to the lesser of the unified credit, or the remaining tax payable.

Return to the Table of Contents at the top of this page

Confusion Remains Over $600,000 "Exemption"

Some confusion apparently remains over the impact of the new tax treaty Protocol on the amount of U.S. property that is now "exempt" from U.S. estate tax. It is not correct to state that every Canadian now has a $600,000 exemption. The laws are complex. Some people will be entitled to an exemption exceeding $600,000 and others will have much less.

As explained in the Fall, 1995 Taxletter, there are three main sections of the tax treaty Protocol that affect the amount of "exemption" you obtain:

  1. The unified tax credit
  2. The marital tax credit
  3. The limited exemption for worldwide estates that do not exceed US $1.2 million.

You can add all these "exemptions" to determine your total exemption.

However, some generalities can be stated because they result automatically from the above rules. These generalities are not rules in themselves, they simply result when you apply the above rules. Assuming you made no prior U.S. taxable gifts:

  1. If your worldwide property does not exceed US $600,000 at the date of death, (including all appropriate property such as RRSP's/RRIF's, life insurance, ongoing pensions, etc.), there will be no U.S. federal estate tax regardless of the value of your U.S. property, and
  2. If all your property is in the United States, it does not exceed US $1,097,073, and it is all owned jointly by you and your spouse (joint tenancy with right of survivorship), there will be no U.S. federal estate tax when you die, provided certain other requirements are met (but your spouse would be exposed to estate tax, should he/she die before selling the property).

Estate tax may still be payable to the individual State. Be sure to consult your tax advisor before making any change, since gift tax or other surprises may result.

Return to the Table of Contents at the top of this page

Elimination Of $70,000 Exclusion For U.S. Citizenship Abroad?

President Clinton has proposed legislation which would eliminate the $70,000 earned income exclusion to which U.S. citizens living outside the U.S. are now generally entitled. However there has been considerable criticism from the business community and therefore the proposal may not be enacted.

Return to the Table of Contents at the top of this page

Possible Estate Tax Strategy For Some

The new tax treaty Protocol provides many new planning opportunities to reduce or eliminate U.S. estate tax. Here is one example.

Recall that in most cases there will be no U.S. estate tax if the decedent's worldwide estate at the date of death does not exceed US $600,000. (See CONFUSION REMAINS OVER $600,000 "EXEMPTION") Therefore, for married couples, in some cases it may be practical to place all U.S. property in the name of one spouse and to ensure that spouse has a worldwide net worth of less than $600,000. With this structure, up to US $600,000 in U.S. property could be owned by the spouse without any U.S. federal estate tax exposure. More possibilities in future Taxletters.

Return to the Table of Contents at the top of this page

U.S. Taxation Of Your U.S. Financial Assets

U.S. tax laws apply to your U.S. financial assets in addition to your U.S. real estate.

Accounts at U.S. Banks and Savings & Loan Associations

Your account at a U.S. bank or Savings & Loan Association is exempt U.S. income tax and also U.S. estate tax provided you are a nonresident alien of the U.S. and the account is not connected with U.S. business. (However, an account opened through a bank-sponsored brokerage firm has different rules - see below). A similar rule exempts certain insurance contracts from U.S. income tax.

The bank may send you IRS Form W-9 or W-8 and ask that you sign it and return it to the bank. Form W-9 is used to report your U.S. taxpayer identification number to the bank, if you have one. Normally you would only have a U.S. taxpayer identification number if you previously filed a U.S. tax return, were engaged in U.S. business, or in some cases, had U.S. tax withheld. The IRS issued a proposal last year which, if implemented, would require you to file IRS Form W-7 to obtain a U.S. number if you received certain types of U.S. income. We will advise you when this is implemented. In the meantime, never insert your Canadian social insurance number on Form W-9 - this will eventually lead to some type of IRS follow-up.

If you do not have a U.S. taxpayer number, (and are not required to have one), you can sign IRS Form W-8 and return it to the bank to cover your interest income.

Accounts at U.S. Stockbrokerage Firms

General rule

As a general rule, you are subject to U.S. income (withholding) tax and U.S. estate tax on the U.S. stocks and bonds in your stockbrokerage account even if the account is in Canada. The 1996 U.S. withholding tax is generally 15% on dividends and 10% on interest. However there are many significant exceptions, some of which are indicated below.

Some Exceptions

Any bank account or Savings & Loan account that is opened through a stockbrokerage firm is exempt if it meets all the rules described in the preceding section. For example, this would apply to a bank certificate of deposit purchased through a stockbrokerage firm.

Assuming you are a non-resident alien of the United States and not engaged in U.S. business, the U.S. tax status of your U.S. stocks, bonds and money market accounts depends upon the nature of the security itself and, in the case of estate tax, your worldwide net worth at your date of death.

In this case, if your worldwide net worth at the date of death does not exceed U.S. $1.2 million or the Canadian equivalent, (and you meet the relevant tax treaty requirements), you will be exempt U.S. estate tax on your U.S. stocks, bonds and money market funds, except for certain real-estate related securities. However you will still be subject to U.S. income tax on the interest or dividends from these securities unless the security is an interest bearing security that qualifies for the "portfolio interest" exemption described below.

If you are a nonresident alien not engaged in U.S. business and you own an interest bearing security that qualifies as a "portfolio interest" obligation that security will be exempt both U.S. income tax and U.S. estate tax. To qualify as a portfolio interest obligation, many complicated requirements apply. Among them, the debt must:

  1. Be issued after July 18, 1984, and
  2. Be in "registered form", (as defined) or
  3. If not registered, the security must meet certain additional requirements.

Among many such securities, it appears likely that recently issued U.S. Treasury Notes and Bonds will qualify.

Also, stockbrokers can offer you certain fixed income mutual funds or trusts which qualify.

Even if your securities are subject to estate tax, there may still be no actual tax payable after applying other provisions of the tax code and the tax treaty.

The stockbroker will also ask you for IRS Form W-9 or W-8, as described above.

Return to the Table of Contents at the top of this page

"Exit Tax" Remains Alive

We previously mentioned proposals to impose a U.S. "exit tax" on U.S. citizens who renounce U.S. citizenship, and "long-time" green card holders who cease being taxed as U.S. residents. Apparently this change continues to gain significant support in both the Congress and the Administration. There are several different varying proposals being considered and it is too early to determine which version (if any) will be implemented. We will keep you updated.

Return to the Table of Contents at the top of this page

More Paper Work If You Are Engaged In U.S. Business

If you are engaged in U.S. business (perhaps including the renting of your U.S. home or condo) you are required to file reports with the IRS on certain payments you make to other individuals. Fines apply if you do not comply.

For example, if you are engaged in U.S. business you must generally file IRS Form 1099-INT with the IRS for any interest payments you make in excess of $600 per recipient in connection with your business. The payment does not have to be reported if the recipient is a corporation.

You must file IRS Form 1099-MISC for payments you make exceeding $600 for rents or services. Again, payments to corporations are generally exempt.

Return to the Table of Contents at the top of this page

Living Trust For Death Transfer Of U.S. Assets


Michael Rosenberg and Mark D. Rich, Attorneys

Tel: 305-665-3311

Aside from the significant estate and gift tax consequences associated with ownership of United States ("U.S.") assets (e.g., U.S. situated real estate and U.S. situated tangible personal property), foreign investors are frequently unaware of the: potentially sizable costs, prolonged delays, asset expropriation risks, disclosures of confidential information, and estate plan disruption, all of which can result upon a nonresident alien decedent's ("NRAD's") death while owning U.S. situated assets.

Upon the death of an NRAD directly and solely owning U.S. situated assets, costly and lengthy probate proceedings, whether testate or intestate, will probably be necessary in the relevant state probate court, in order to effect the disposition of such assets. Moreover, many NRAD's are concerned about the confidentiality "back home" of their actions and investments outside their home jurisdiction. However, they are unaware of the ways that probate proceedings may result in breaches of such confidentiality, conceivably resulting in home jurisdiction expropriation of assets and/or harassment of surviving family members. In addition, estate plan disruptions are also a real possibility in such instances.

For example, the laws of many civil law jurisdictions, if applied, would require or "force" distribution of a share of an NRAD's assets to specific predetermined individuals such as children (these are often referred to as "forced heirship" laws), notwithstanding provisions to the contrary in the NRAD's will.

Proper advice and careful planning can eliminate many of the foregoing difficulties and concerns. A trust structure (domestic or foreign, and revocable or irrevocable, depending on the foreign investor's unique needs) may often be the optimum solution. Like a will, a trust can:

  1. Provide specifically for only selected beneficiaries while excluding others;
  2. Impose tailor-made status conditions on trust shares of beneficiaries in order to fulfill specific purposes {e.g., an un-remarried widow; a surviving child or grandchild; a U.S. citizen or resident alien ("RA") versus a nonresident alien ("NRA"); a U.S. citizen or resident alien decedent ("RAD") versus and NRAD] and
  3. Depending on the type of trust and form of assets involved, retain for the NRA absolute control until his death.

Unlike a will, a trust, if properly structured and created prior to the NRAD's death, will achieve two additional desirable results:

  1. It will be operative and will accomplish the legal titling of his various property interests in the trustee(s) while the NRA is still around to confirm to third parties dealing with the trustee(s) that the trustee(s) (of which the NRA may be one) are in fact authorized to take title to those assets; and
  2. Upon his death, it can reduce or even eliminate the risks of undesired communications with the country of foreign domicile and the risk of undesired application of such foreign domicile's laws.

The trust structure, when coordinated with proper advance planning, can also result in significant U.S. estate, gift and generation-skipping transfer tax minimization and/or avoidance.

Return to the Table of Contents at the top of this page

*Applicable to residents of Canada only---addresses only U.S. Federal Issues---State and local issues may also apply. The information herein is provided for your general information. Action should not be taken on the basis of this letter. Action should only be taken on the advice of your professional advisor applying these rules to your specific situation.

©Brunton's U.S. Taxletter For Canadians

Search | Contents | FAQ | Order Handbook | E-mail

Law Office of Joseph C. Grasmick
Business Immigration
Cyclorama Building
369 Franklin Street Suite 300
Buffalo, New York 14202-1725 U.S.A.
Tel: 716.842.3100
Fax: 716.842.3105

This Internet Web page is