Larry Stolberg CPA

From U S compliance for annual 1040 tax return filings for U S citizens/green card holders to IRS streamlined applications (catch-up), FBARs/FINCEN114, to expatriation, to businesses expanding/operating in either country, to Canadians or non-residents buying their first U S /Canadian rental property to snowbirds , I can assist in the process Moving to/or from Canada or to/from the U S is dealt with on a regular basis

I am also an IRS Certified Acceptance Agent able to assist in obtaining an ITIN (individual taxpayer identification number)

Engagements for business owners and other interested parties Including the tax services noted above, preparation of unaudited financial statements and Canadian corporate T2 or T1 personal tax returns to meet your compliance needs may be provided as well as dealing with CRA appeals/disputes and filing notices of objection Corporation restructuring or determination if you qualify for investment tax credit for doing research & development is another possibility

Please review the detailed services tab included in the “Services Tab” for additional services provided

Some of the routine areas that I may deal with are:

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• Applying for our Canadian voluntary disclosure procedures to waive penalties and interest with respect to outstanding returns and prescribed forms
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• Appealing your notice of (re)assessment to obtain a more favourable result where indicated
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• Dealing with collection officers to obtain reasonable payment terms and\or to remove liens and requirements to pay orders
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• Meeting with officials to negotiate on your behalf U
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• streamlined & OVDP procedures for U
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• persons in respect to past-due tax returns, international information returns, FBARS (FINCEN114), etc

I may deal with various techniques to minimize your otherwise potential tax burden arising on your passing From assistance with WILL preparation, to corporate restructuring, to post-mortem planning or simply just to T1/T3 tax return preparation- I can assist in the process

Succession planning in dealing with transfer of business to next generation is dealt with on a regular basis

I deal with various restructuring options from estate planning, to purification to enhance the your ability to obtain the capital gains exemption, to entry of family members or key employees as shareholders, to inter-generational farm transfers, to consolidation to simplify your present structure and reduce your annual fees, to access to small business deduction, to assistance with structuring a shareholders agreement & corporate-owned life insurance or even incorporation of professional corporations to that of proprietorships or partnerships-I can assist in the process

I deal with various issues applying to individuals residing or working as employees or on a contractual basis in either Canada or the United States as well Canadian businesses or U S businesses wishing to expand into the other country It is not unusual to get into a structure and find out latter that it is not only not tax effective but you have increased your annual compliance fees significantly Cross border payments and domestic laws and TREATY application are an a important part of the analysis! Remember it is not always what you make, it is what you keep or retain Repatriation of funds is an important element

Cross border payments may include various types of income such as management fees, dividends, interest, royalties or pensions/annuities In some situations, the Canada/U S tax treaty will exempt or reduce the U S 30% withholding tax In this regard, you generally would require an IRS issued waiver form such as the W8-Ben Sometimes you may need a U S ITIN If tax is over withheld, you need to file a U S return to get the refund which can be avoided if you deal with the situation at the outset Canada will not provide credit for excess withholding if it was due to you not claiming an available TREATY provision

From U S compliance for annual foreign information returns to 1040 tax return filings for U S citizens/green card holders to IRS streamlined applications (catch-up), FBARs/FINCEN114, to expatriation, to Canadians or non-residents buying their first U S /Canadian rental property and their 1040NR filings, to U S corporate (protective) filings because you are carrying on business in the U S , I can assist in the process Moving to/or from Canada or to/from the U S is dealt with on a regular basis

Canadians who wish to reside in the U S for the winter months should be aware of the U S residency rules If you fall into these rules, you could be resident for U S income tax purposes and therefore be subject to U S tax on your world income unless you file the appropriate forms for exemptions

Review the detailed article on Snowbirds contained in the Resources section-U S Taxation

I can help you with the transfer of farmland, quotas, equipment and shares of a family farm corporation

Did you know that the Ontario Soil and Crop Improvement Association has a subsidy program to assist you with professional fees for succession planning For an established farm business, they may finance 50% of the costs under the capacity building program You may contact them at 1-800-265-97511-800-265-9751 FREE for additional information and/or access their website http://www ontariosoilcrop org/en/programs/growing_forward_2_new htm Please refer to my article in the Canadian Taxation Resources section at the top of the home page

For a number of years, provincial governing bodies of regulated health professionals (1) and other professional organizations (2) have allowed the incorporation of the professional practice The major tax advantage of incorporation, is the ability to defer tax by retaining income in the corporation that would otherwise be taxed at a much higher personal tax rate if you earned the same income as a sole proprietor or as a partner

Refer to my article on professional corporations in the Canadian Taxation Resources section

If you are renting your U S real property via a management company or are listing for sale your U S property, you will need an ITIN Canadian individual partners of a U S Limited Partnership will also need an ITIN If you are only in receipt of say U S source income such as royalties, pension, dividends or interest that is not handled by a Canadian broker, the U S withholding agent may require you to have an ITIN

Please refer to my articles in the resources section on U S Taxation, rental or sale of U S real property and the article in the services section on the ITIN

U S persons including U S citizens or green card holders residing in Canada who are not up to date with their U S filing obligations should consider the available programs in an effort to become tax-compliant

The updated streamlined procedures announced on June 18, 2014 modified changes to the 2012 streamlined program, now known as the Streamlined Foreign Offshore Program (“SFOP”) requiring the filing of 3 years of past-due returns (with required disclosures and international information returns) plus 6 years of FBARs

There were also modifications to the 2012 Offshore Voluntary Disclosure Program (“OVDP”) and a new streamlined procedure called Streamlined Domestic Offshore Program for U S persons residing in the United States