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About Derren

Derren has successfully completed the Comparative Tax Program at Harvard University and is an EA (Enrolled Agent). As an EA, he has been admitted to practice before the Internal Revenue Service (IRS) to represent taxpayers in all 50 states and internationally. He has 2 Masters Degrees in Economics and a Certified Diploma from the ACCA (Association of Chartered Certified Accountants in the UK).

Derren has also done Executive Education with Columbia Business School, and has completed Advanced Tax coursework at both New York University and the University of London.

He had his views published in the Singapore Business Review, Forbes Asia, and the American Chamber of Commerce in Indonesia, the International Business Structuring Association (in the UK), Offshore Alert, and the (Trinidad) Guardian. And has given “in person” seminars on tax issues in the U.S., the U.K., Singapore, Indonesia, Malaysia, Vietnam, The Philippines, Portugal, Hong Kong, UAE, and the Caribbean.

Derren is currently a member of the Briefing Group advising The Rt. Hon. The Lord Mayor of the City of London on current and emerging international tax issues. Derren enjoys writing and has published 3 books on taxation, one of which was an Amazon Best Seller in 2020.

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[ Offshore Tax ] Which tax rules changed in Puerto Rico?

At the beginning of 2012, the Government of Puerto Rico implemented two acts that were part of a set of economic incentives intended to improve the conditions of this Caribbean island’s economy.
Act 20 and Act 22, also known as the Export Services Act and the Individual Investors Act, respectively, were put in place to facilitate Puerto Rico’s economic development by attracting high-net-worth individuals and businesses to the island through the multitude of tax benefits that these acts offered.
Act 20 program was designed to enable eligible businesses to use various tax exemptions as long as the business is based in Puerto Rico and has its clients located outside of Puerto Rico.
Exempt businesses benefit from a mere 4% corporate tax rate, a 100% tax exemption on dividend distributions, and other tax advantages that will be discussed below.
On the other hand, Act 22 aims to promote investment in Puerto Rico by offering investors who are bona fide residents extremely profitable tax incentives. The income that these investors accrue on dividends, interests, all capital gains, and even all crypto assets, after meeting all the requirements of residency, is exempt from taxation.
Act 20 and Act 22 were integrated into the Puerto Rico Incentives Code 60, or Act 60, as two separate chapters on January 1, 2020.
This change came with a few adjustments to the qualification requirements of each program.
These highly attractive tax incentives have been possible due to Puerto Rico’s unique relationship with the United States.
Being an unincorporated U.S. territory with a commonwealth status, the Puerto Rican government has the advantage of creating its own tax laws that are distinct from the U.S. federal or state laws. This independence has allowed Puerto Rico to stimulate economic growth through the Act 60 program.

TIMESTAMPS:
0:00 INTRO
0:20 Big changes on tax rules in Puerto Rico
1:00 Small businesses taxes in Puerto Rico
2:00 Residency in Puerto Rico
3:02 OUTRO


------------------------------------------------

OUR CHANNEL OFFERS:
- Updated daily, we help 6, 7, and 8-figure International Entrepreneurs, Expats, Digital Nomads, and Investors legally minimize their global tax burden and protect their wealth.
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--------------------------------------------------
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https://youtu.be/yKIQ78azSA8
https://youtu.be/pBvgddn4VQ4
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High Net Worth? We can QUOTE for doing your "US-International" tax returns.

 FOR MORE DETAILS, CONNECT WITH US:
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#puertorico #taxrules #taxesPuertoRico #investors #offshorecitizen #nomadcapitalist  #flagtheory #InternationalEntrepreneur #irs #offshorebanking #ibc #offshorecompany

[ Offshore Tax ] Which tax rules changed in Puerto Rico?

At the beginning of 2012, the Government of Puerto Rico implemented two acts that were part of a set of economic incentives intended to improve the conditions of this Caribbean island’s economy.
Act 20 and Act 22, also known as the Export Services Act and the Individual Investors Act, respectively, were put in place to facilitate Puerto Rico’s economic development by attracting high-net-worth individuals and businesses to the island through the multitude of tax benefits that these acts offered.
Act 20 program was designed to enable eligible businesses to use various tax exemptions as long as the business is based in Puerto Rico and has its clients located outside of Puerto Rico.
Exempt businesses benefit from a mere 4% corporate tax rate, a 100% tax exemption on dividend distributions, and other tax advantages that will be discussed below.
On the other hand, Act 22 aims to promote investment in Puerto Rico by offering investors who are bona fide residents extremely profitable tax incentives. The income that these investors accrue on dividends, interests, all capital gains, and even all crypto assets, after meeting all the requirements of residency, is exempt from taxation.
Act 20 and Act 22 were integrated into the Puerto Rico Incentives Code 60, or Act 60, as two separate chapters on January 1, 2020.
This change came with a few adjustments to the qualification requirements of each program.
These highly attractive tax incentives have been possible due to Puerto Rico’s unique relationship with the United States.
Being an unincorporated U.S. territory with a commonwealth status, the Puerto Rican government has the advantage of creating its own tax laws that are distinct from the U.S. federal or state laws. This independence has allowed Puerto Rico to stimulate economic growth through the Act 60 program.

TIMESTAMPS:
0:00 INTRO
0:20 Big changes on tax rules in Puerto Rico
1:00 Small businesses taxes in Puerto Rico
2:00 Residency in Puerto Rico
3:02 OUTRO


------------------------------------------------

OUR CHANNEL OFFERS:
- Updated daily, we help 6, 7, and 8-figure International Entrepreneurs, Expats, Digital Nomads, and Investors legally minimize their global tax burden and protect their wealth.
- Join Amazon's best-selling author, Derren Joseph, in exploring the offshore financial world.

SUBSCRIBE TO OUR CHANNEL FOR MORE FREE INFORMATION:
https://www.youtube.com/c/TaxesforInternationalEntrepreneursandExpats?sub_confirmation=1
--------------------------------------------------
WATCH OTHER VIDEOS:
https://youtu.be/aec2se0x_cs
https://youtu.be/yKIQ78azSA8
https://youtu.be/pBvgddn4VQ4
--------------------------------------------------
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High Net Worth? We can QUOTE for doing your "US-International" tax returns.

FOR MORE DETAILS, CONNECT WITH US:
✉ Contact us at help@advancedamericantax.com
--------------------------------------------------
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🌍 Check our website: https://htj.tax/
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#puertorico #taxrules #taxesPuertoRico #investors #offshorecitizen #nomadcapitalist #flagtheory #InternationalEntrepreneur #irs #offshorebanking #ibc #offshorecompany

YouTube Video VVVRTDRWUGxzSTJKZXdnSHpyeG82SE13LmEzZlBibG9mN0NR

[ Offshore Tax ] Which tax rules changed in Puerto Rico?

21 hours ago

[ Offshore Tax ] Is Earned Income tax-free in Puerto Rico?

As a US citizen, you're subject to US tax on your worldwide income, whether you live inside the US or outside the US. Of course, many tax incentives are available for ex-pats, like the foreign earned income exclusion, foreign tax credit, and the ability to operate a business through a non-US corporation.
However, if you become a "bona fide resident of Puerto Rico," you're no longer subject to US federal income tax on your Puerto Rico source income. Instead, you're only subject to Puerto Rican income tax on that income.
Then, under a law referred to as Act 60 (formerly Act 20 and Act 22), Puerto Rico has enacted several tax incentives, the two most popular of which are as follows:
a Puerto Rican corporation engaged in certain types of service businesses only pays a Puerto Rican tax of 4%.
You pay 0% tax on certain dividends and capital gains you realize while you're a bona fide resident of Puerto Rico.

TIMESTAMPS:
0:00 INTRO
0:30 Earned income taxes in Puerto Rico
2:30 Capital gains taxes in Puerto Rico
3:37 Corporate Taxes in Puerto Rico
4:55 OUTRO



------------------------------------------------

OUR CHANNEL OFFERS:
- Updated daily, we help 6, 7, and 8-figure International Entrepreneurs, Expats, Digital Nomads, and Investors legally minimize their global tax burden and protect their wealth.
- Join Amazon's best-selling author, Derren Joseph, in exploring the offshore financial world.

SUBSCRIBE TO OUR CHANNEL FOR MORE FREE INFORMATION:
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--------------------------------------------------
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https://youtu.be/kT6XTNvlQW0
https://youtu.be/coaMpkZh8Jc
https://youtu.be/KbnD_XWyHls
--------------------------------------------------
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High Net Worth? We can QUOTE for doing your "US-International" tax returns.

 FOR MORE DETAILS, CONNECT WITH US:
✉ Contact us at help@advancedamericantax.com
--------------------------------------------------
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DERREN JOSEPH:
If you have state source income from one of the other states or territories, there'll be a subject to tax as it normally would be. And you also mentioned it's particularly attractive to those who enjoy passive income, interest dividends, and capital gains. But if you have Earned income, so for example, let's say you're a consultant and you sit in Puerto, Rico, that income, that Earned income would also be tax-free.

GIANCARLO ESQUILIN:
Yeah, well basically the Earned income and the service income board are not free nor tax-free. There are tax benefits for that. And basically, that's another disposition that was previously under Act 20. Now under Act 60 and the Export Service Act or the export tax benefits, that basically allows a company or an individual to relocate to Puerto Rico or open a new company in Puerto, Rico and export services from Puerto Rico to any part of the world. So if they provide the services while working in Puerto Rico that you can say, Hey, if you provided the services in Puerto Rico, that's Puerto Rico source income as described by the Puerto Rico tax code and the US tax code, that will be subject to a preferential tax rate of 4% tax. That is a flat tax of 4% tax. And if it is a company and the income that is generated is subject to the 4% tax dividend paid by that income from that corporation is fully accepted. So that basically means that certainly if there is an owner-employee, you need to analyze if they need to have a regional compensation that he needs to pay their social security Medicare taxes, some kind of income taxes on his board. But certainly, dividends pay from return earnings accumulated from the export service activity are exempt at the individual level. So one of the best strategies, certainly to, if the owner is a Puerto Rico, one of five resident, and the corporation that provide the services is a Puerto Rico entity, entity Dividends paid by that corporation are treated like Puerto Rico source income under the eyes of the IRS. You will pay, or the company will pay 4% tax dividends received by the owner will be fully exempt at Puerto Rico and federal levels. 

#puertorico #taxfree #taxesPuertoRico #investors #offshorecitizen #nomadcapitalist  #flagtheory #InternationalEntrepreneur #irs #offshorebanking #ibc #offshorecompany

[ Offshore Tax ] Is Earned Income tax-free in Puerto Rico?

As a US citizen, you're subject to US tax on your worldwide income, whether you live inside the US or outside the US. Of course, many tax incentives are available for ex-pats, like the foreign earned income exclusion, foreign tax credit, and the ability to operate a business through a non-US corporation.
However, if you become a "bona fide resident of Puerto Rico," you're no longer subject to US federal income tax on your Puerto Rico source income. Instead, you're only subject to Puerto Rican income tax on that income.
Then, under a law referred to as Act 60 (formerly Act 20 and Act 22), Puerto Rico has enacted several tax incentives, the two most popular of which are as follows:
a Puerto Rican corporation engaged in certain types of service businesses only pays a Puerto Rican tax of 4%.
You pay 0% tax on certain dividends and capital gains you realize while you're a bona fide resident of Puerto Rico.

TIMESTAMPS:
0:00 INTRO
0:30 Earned income taxes in Puerto Rico
2:30 Capital gains taxes in Puerto Rico
3:37 Corporate Taxes in Puerto Rico
4:55 OUTRO



------------------------------------------------

OUR CHANNEL OFFERS:
- Updated daily, we help 6, 7, and 8-figure International Entrepreneurs, Expats, Digital Nomads, and Investors legally minimize their global tax burden and protect their wealth.
- Join Amazon's best-selling author, Derren Joseph, in exploring the offshore financial world.

SUBSCRIBE TO OUR CHANNEL FOR MORE FREE INFORMATION:
https://www.youtube.com/c/TaxesforInternationalEntrepreneursandExpats?sub_confirmation=1
--------------------------------------------------
WATCH OTHER VIDEOS:
https://youtu.be/kT6XTNvlQW0
https://youtu.be/coaMpkZh8Jc
https://youtu.be/KbnD_XWyHls
--------------------------------------------------
Here are 4 ways we can help you:
SIGN UP for free webinars on US Expat Taxes and International Entrepreneur Taxes: https://htj.tax/events/
STREAM premium educational videos: https://htj.tax/youtube/
CONTACT us for tax optimization consults over Zoom: https://www.htj.tax/contact/
High Net Worth? We can QUOTE for doing your "US-International" tax returns.

FOR MORE DETAILS, CONNECT WITH US:
✉ Contact us at help@advancedamericantax.com
--------------------------------------------------
FOLLOW US ON:
🌍 Check our website: https://htj.tax/
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#puertorico #taxfree #taxesPuertoRico #investors #offshorecitizen #nomadcapitalist #flagtheory #InternationalEntrepreneur #irs #offshorebanking #ibc #offshorecompany

YouTube Video VVVRTDRWUGxzSTJKZXdnSHpyeG82SE13LmFlYzJzZTB4X2Nz

[ Offshore Tax ] Is Earned Income tax-free in Puerto Rico?

February 4, 2023 10:00 am

[ Offshore Tax ] What is the main tax advantage of moving to Puerto Rico?

The Tax Incentive Code, known as “Act 60”, provides tax exemptions to businesses and investors that relocated to or are established in Puerto Rico. The incentives are particularly attractive to U.S. citizens who moved to Puerto Rico because they do not need a residency permit. Likewise, their Puerto Rico-sourced income is exempt from U.S. federal and state income taxes.
They also get to keep benefits such as Medicare and Social Security. Furthermore, the Puerto Rican tax code mirrors the U.S. Internal Revenue Code, making the transition much easier for those who became bona fide residents of Puerto Rico.
The U.S. tax code (Section 933) allows a bona fide resident of Puerto Rico to exclude Puerto Rico-source income from their U.S. gross income for U.S. tax purposes. If the income was received from sources outside Puerto Rico, then a U.S. federal tax return must be filed if the income earned outside of Puerto Rico exceeds the taxpayer’s filing threshold.
Any U.S.-sourced income is still subject to U.S. taxes at the regular rate, but under the tax exemption decrees, Puerto Rico-sourced income for an individual may be taxed at 0% for Federal and Puerto Rican tax purposes. Puerto Rico-sourced income may include interest and dividends from sources in Puerto Rico.

TIMESTAMPS:
0:00 INTRO
0:10 What are the main benefits of moving to Puerto Rico
1:00 Political  and taxes situation in Puerto Rico
1:55 Manufacturing and services in Puerto Rico
2:25 Tax benefits moving to Puerto Rico
4:23 OUTRO



------------------------------------------------

OUR CHANNEL OFFERS:
- Updated daily, we help 6, 7, and 8-figure International Entrepreneurs, Expats, Digital Nomads, and Investors legally minimize their global tax burden and protect their wealth.
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--------------------------------------------------
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https://youtu.be/KbnD_XWyHls
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High Net Worth? We can QUOTE for doing your "US-International" tax returns.

 FOR MORE DETAILS, CONNECT WITH US:
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--------------------------------------------------
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DERREN JOSEPH
So what is the main attractiveness of, obviously Puerto Rico is a beautiful territory, a beautiful island, right? But, as a jurisdiction, what is the main benefit of moving to Puerto Rico from the US?

GIANCARLO ESQUILIN:
Yeah. Well, let me give you some political status. What means to, in Puerto Rico is a territory of the United States, but being a territory we have some particular exemptions, but okay, Puerto Ricans are born and raised or US citizens by per, so that means that, you know, you pay taxes to the US based on citizenship, but there is a particular situation in the case of Puerto Rico bonafide residents. Right? And Puerto Rico bonafide residents are particularly defined or provided by section 937 of the US tax code. And that basically allows Puerto Rico bonafide residents who do not pay us taxes on Puerto Rico source income, but it's Puerto Rico source income only based on section 933. So those are the main two sections that allows Puerto Rico residents to not pay US taxes. But that doesn't mean that if you generate income from other sources, internet dividends if you have a rental home in the US, that means US source income. So even if you live in Puerto Rico, you may be saving for US or state income taxes. Okay. One of the principal benefits of moving in or living in Puerto Rico, for income taxes is those tax benefits that the Puerto Rico government has been offering for decades. Now, there is an evolution from manufacturing activities to pharma airplanes, systems, and services. And since 2012, basically Puerto Reconnected Act training and 22, that is now Act 60. 

#puertorico #movingtoPuertoRico #taxesPuertoRico #investors #offshorecitizen #nomadcapitalist  #flagtheory #InternationalEntrepreneur #irs #offshorebanking #ibc #offshorecompany

[ Offshore Tax ] What is the main tax advantage of moving to Puerto Rico?

The Tax Incentive Code, known as “Act 60”, provides tax exemptions to businesses and investors that relocated to or are established in Puerto Rico. The incentives are particularly attractive to U.S. citizens who moved to Puerto Rico because they do not need a residency permit. Likewise, their Puerto Rico-sourced income is exempt from U.S. federal and state income taxes.
They also get to keep benefits such as Medicare and Social Security. Furthermore, the Puerto Rican tax code mirrors the U.S. Internal Revenue Code, making the transition much easier for those who became bona fide residents of Puerto Rico.
The U.S. tax code (Section 933) allows a bona fide resident of Puerto Rico to exclude Puerto Rico-source income from their U.S. gross income for U.S. tax purposes. If the income was received from sources outside Puerto Rico, then a U.S. federal tax return must be filed if the income earned outside of Puerto Rico exceeds the taxpayer’s filing threshold.
Any U.S.-sourced income is still subject to U.S. taxes at the regular rate, but under the tax exemption decrees, Puerto Rico-sourced income for an individual may be taxed at 0% for Federal and Puerto Rican tax purposes. Puerto Rico-sourced income may include interest and dividends from sources in Puerto Rico.

TIMESTAMPS:
0:00 INTRO
0:10 What are the main benefits of moving to Puerto Rico
1:00 Political and taxes situation in Puerto Rico
1:55 Manufacturing and services in Puerto Rico
2:25 Tax benefits moving to Puerto Rico
4:23 OUTRO



------------------------------------------------

OUR CHANNEL OFFERS:
- Updated daily, we help 6, 7, and 8-figure International Entrepreneurs, Expats, Digital Nomads, and Investors legally minimize their global tax burden and protect their wealth.
- Join Amazon's best-selling author, Derren Joseph, in exploring the offshore financial world.

SUBSCRIBE TO OUR CHANNEL FOR MORE FREE INFORMATION:
https://www.youtube.com/c/TaxesforInternationalEntrepreneursandExpats?sub_confirmation=1
--------------------------------------------------
WATCH OTHER VIDEOS:
https://youtu.be/kT6XTNvlQW0
https://youtu.be/coaMpkZh8Jc
https://youtu.be/KbnD_XWyHls
--------------------------------------------------
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SIGN UP for free webinars on US Expat Taxes and International Entrepreneur Taxes: https://htj.tax/events/
STREAM premium educational videos: https://htj.tax/youtube/
CONTACT us for tax optimization consults over Zoom: https://www.htj.tax/contact/
High Net Worth? We can QUOTE for doing your "US-International" tax returns.

FOR MORE DETAILS, CONNECT WITH US:
✉ Contact us at help@advancedamericantax.com
--------------------------------------------------
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🌍 Check our website: https://htj.tax/
🎙️ Listen to our podcast: https://podcast.htj.tax/
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🐦 Add us on Twitter: https://twitter.com/derren43/
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#puertorico #movingtoPuertoRico #taxesPuertoRico #investors #offshorecitizen #nomadcapitalist #flagtheory #InternationalEntrepreneur #irs #offshorebanking #ibc #offshorecompany

YouTube Video VVVRTDRWUGxzSTJKZXdnSHpyeG82SE13LnlLSVE3OGF6U0E4

[ Offshore Tax ] What is the main tax advantage of moving to Puerto Rico?

February 3, 2023 10:00 am

[ Offshore Tax ] Taxation of Crypto in Canada.

Canadians do not have to pay taxes for buying or holding cryptocurrency. Taxpayers are subject to pay capital gains or business income tax after selling or mining cryptocurrency. The percentage of net taxable profits depends on whether the profits are classified as capital gains or business income.

TIMESTAMPS:
0:00 INTRO
0:10 Crypto on NFTs taxes in Canada
1:00 Taxpayers are subject to pay capital gains 
2:50 OUTRO

------------------------------------------------

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High Net Worth? We can QUOTE for doing your "US-International" tax returns.

 FOR MORE DETAILS, CONNECT WITH US:
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--------------------------------------------------
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DERREN JOSEPH:
Crypto, Crypto. NFTs. How does, and again, I know it's a super broad topic, but generally speaking, how does the CRA look at Crypto and NFTs?

BALCHANDER PUDUKKOTAI:
I think right now, the way they're, they're doing a lot of their own research and trying to see what's the best way to tax it, but I think they're kind of considering that as property, if I'm not mistaken, and saying that this is a property that you own and there's an increase in the value, and if you're disposing of that property, then they should be, now we are not clear at this point whether they treat it as a capital gain or as a business income or what they're going be treating it as. So other than in general terms, saying that they're looking at it as a property and taxing it on that basis, I, that's, that's what I can comment on. Kul. Any insight on anything else?

KUL MAKKAR:
No, I, in fact, I read some time back and, and it, you know, it CRA did mention as I pointed out, that it will be treated as a property and you know, has to be reported if there are any gains on that. But I think there are more clarifications, there are more, you know, more details are expected from CRA on this. That's what I think it's still a lot of, you know, non-clarity. In fact, people, some of our clients, do come to us and ask about how to report that. So we've, you know, that's still a territory which has to be kinda really kinda understood a little more before we can give some context that.

DERRN JOSEPH:
Okay. Gentlemen, thank you very much. I appreciate you sharing some of your time, your expertise, and your insight. If someone wanted to follow up on some of these issues and reach out to you guys directly, what's the best way to reach out here?

BALCHANDER PUDUKKOTAI:
They can reach me through my email, which is bk ca or they can, I have clients using WhatsApp and calling me and letting me know, can you set up a meeting as well? So as long as they have the phone number, my phone number, just which I can share with you then afterward, so, okay. Let's, yeah.

DERREN JOSEPH:
Fantastic.

BALCHANDER PUDUKKOTAI:
And Kul.

KUL MAKKAR
Yeah, I would say the same thing. In fact, I would suggest that if, you know, they can reach out to Derren, Derren has all the details about me, exactly my email and my phone number. And I'll be very happy to answer the questions and if they need any consultancy, if they need any advice, we'd be happy to provide that as well.

DERREN JOSEPH:
Okay, wonderful.

OUTRO:
So if you're a six, seven, or eight-figure investor, entrepreneur, or business owner who needs a tailor-made solution from a qualified team of professionals, we can help you achieve the international lifestyle, the freedom, and even the tax savings you're looking for. Visit us at HTJ.tax and live that international life.

#cryptoCanada #cryptotaxes #taxesCanada #investors #offshorecitizen #nomadcapitalist  #flagtheory #InternationalEntrepreneur #irs #offshorebanking #ibc #offshorecompany

[ Offshore Tax ] Taxation of Crypto in Canada.

Canadians do not have to pay taxes for buying or holding cryptocurrency. Taxpayers are subject to pay capital gains or business income tax after selling or mining cryptocurrency. The percentage of net taxable profits depends on whether the profits are classified as capital gains or business income.

TIMESTAMPS:
0:00 INTRO
0:10 Crypto on NFTs taxes in Canada
1:00 Taxpayers are subject to pay capital gains
2:50 OUTRO

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[ Offshore Tax ] Taxation of Crypto in Canada.

February 2, 2023 10:00 am

[ Offshore Tax ] What if you are a Canadian tax resident with US LLCs?

The T1134 and T1135 are Canadian foreign information returns like the U.S. 8938, 5471, or 8865.
A number of Canadians are investing in the U.S. with a U.S. limited partnership whose limited partners are solely Canadian residents, and the general partner is a U.S. C corporation whose shareholders are also Canadian residents.
For those who want limited liability protection, this type of investment vehicle is often proposed because the conventional U.S. LLC does not work or is not treaty-friendly for inbound investment into the United States from the Canadian perspective.

TIMESTAMPS:
0:00 INTRO
0:12 US LLCs  taxes in Canada
2:00 The T1134 and T1135 are Canadian foreign 
3:00 Potential tax implications of US LLCs in Canada
5:00 CFC rules in Canada
6:22 OUTRO

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DERREN JOSEPH:
So, at the bottom of the list for US Expats living in Canada, are there any reporting requirements to the CRA when this US ex-pat in Canada has a US LLC back in the US? He says it's in the startup phase, but he has a company outside of Canada.


BALCHANDER PUDUKKOTAI:
Okay. One of the things that are required right now is basically if, if the Canadian taxpayer has income or assets, anything over a hundred thousand dollars Canadian, they're supposed to be reporting the foreign investments and foreign businesses as well so that that reporting requirement is there. And again, given the data sharing and information, there was a time when people it was not enforced that strictly, and now they are actually looking at it. So one of the questions that we do have for most of, for all our clients is that you have any assets that are over a hundred thousand dollars outside of Canada. If so, we need to get details. This could include having bank balances, investments, and shares in businesses outside. And there are certain exceptions. So we just go through that and say what has to be reported in that, that would be reported under what we call the four five. Kul?

KUL MAKKAR:
Yes, Paula? I would also wanna add that since that person owns an LLC in Canada or in the US, also like treated as a disregarded entity, and that adds two complications when, and how to report that. I'm assuming that the person is a Canadian tax Resident and if that person is then there is, there could be an additional reporting requirement on what is called a form E1134, where that person has an interest or ownership in a corporation outside of Canada. Yeah. So the reason I'm highlighting LLC here is that you know, so whether it'll be a T 1 34 or T1 35 would depend on how that disregarded entity LLC is, you know, reported in Canada. But there are reporting requirements and if it is T3 four, then it is, it has been since last year. The reporting has become very complex and very detailed. Again, I would suggest that if you know that this person should, should seek some advice based on how to report that ownership in LMC. It is, it is significant reporting now and there are penalties attached to it.


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[ Offshore Tax ] What if you are a Canadian tax resident with US LLCs?

The T1134 and T1135 are Canadian foreign information returns like the U.S. 8938, 5471, or 8865.
A number of Canadians are investing in the U.S. with a U.S. limited partnership whose limited partners are solely Canadian residents, and the general partner is a U.S. C corporation whose shareholders are also Canadian residents.
For those who want limited liability protection, this type of investment vehicle is often proposed because the conventional U.S. LLC does not work or is not treaty-friendly for inbound investment into the United States from the Canadian perspective.

TIMESTAMPS:
0:00 INTRO
0:12 US LLCs taxes in Canada
2:00 The T1134 and T1135 are Canadian foreign
3:00 Potential tax implications of US LLCs in Canada
5:00 CFC rules in Canada
6:22 OUTRO

------------------------------------------------

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YouTube Video VVVRTDRWUGxzSTJKZXdnSHpyeG82SE13LllVc3NYWVlhZTNF

[ Offshore Tax ] What if you are a Canadian tax resident with US LLCs?

February 1, 2023 6:29 pm

[ Offshore Tax ] Tax planning for Americans working temporarily in Canada

A PFIC is a non-U.S. corporation with at least 75% of its gross income considered passive income or at least 50% of the company's assets are investments that produce passive income. Passive income generally includes dividends, interest, rent, royalties, and capital gains from the disposition of securities.

TIMESTAMPS:
0:00 INTRO
0:10 American working in Canada temporarily
1:00 Tax planning for US ex-pats in Canada
1:55 Avoiding investment products in Canada
2:26 OUTRO



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DERREN JOSEPH:
The other way. Now, if I'm an American who's working Temporarily in Canada, what tax planning should I be joining?

BALCHANDER PUDUKKOTAI:
Okay. If you're an American, first of all, you're, I'm assuming that it's a non, you're a non-resident and just working here in Canada. So the Canadian taxes would be only, on the earnings right here in Canada. But the US side of it, I guess would be the worldwide income. So you'd have to consider that. So the same concept would apply again. Kul, Any other additional things that we can think of in that area?

KUL MAKKAR:
Yep. If we consider that, you know, that working means employment, and then the employment clause that dependent services clause in the treaty has, has some relief. If you are here for less than 60 days and you know the salary income is borne by the employer in the US, then probably you would be able to avoid Canadian taxes. But it's, again, it's not tax planning that I'm suggesting. It's just, you know, what is there under the law for tax planning. There are limited avenues. I would not suggest you do, you know, registered retirement saving plans that most of Canadians use. What is called RST because then there are more issues when you go back to the US that would be taxed. So, but you know, if we have more facts and there could be, you know, certain things that can be planned here, but we need more details to be, to be able to answer some, you know, more specifically in this situation.

DERREN JOSEPH:
Hmm. Yeah. But generally speaking, for Americans working outside of the US, that is definitely what you've just said. That's one of the first things we get into avoiding investment products in, in another jurisdiction. Until you're absolutely sure I'll be treated in both by that jurisdiction and back in the US because a lot of things that are tax advantage in another jurisdiction, there'll be tax penalties free back in the US. And speaking specifically about the PFI designation, the pacifier investment companies, and it is un unfavorable depending on the situation, can be the unfavorable tax treatment of collective investment vehicles or mutual funds unitrust, in other jurisdictions. So something to consider.

OUTRO:
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#taxplanning #workingCanada #taxesCanada #investors #offshorecitizen #nomadcapitalist  #flagtheory #InternationalEntrepreneur #irs #offshorebanking #ibc #offshorecompany

[ Offshore Tax ] Tax planning for Americans working temporarily in Canada

A PFIC is a non-U.S. corporation with at least 75% of its gross income considered passive income or at least 50% of the company's assets are investments that produce passive income. Passive income generally includes dividends, interest, rent, royalties, and capital gains from the disposition of securities.

TIMESTAMPS:
0:00 INTRO
0:10 American working in Canada temporarily
1:00 Tax planning for US ex-pats in Canada
1:55 Avoiding investment products in Canada
2:26 OUTRO



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YouTube Video VVVRTDRWUGxzSTJKZXdnSHpyeG82SE13LmVJLVNvV3pKMTBN

[ Offshore Tax ] Tax planning for Americans working temporarily in Canada

January 31, 2023 10:00 am

[ Offshore Tax ] Foreign Tax Credits of US tax on Canadian returns.

Claiming a foreign tax credit is the primary way Canadian residents can avoid paying double tax on foreign income. Still, the ability to claim a foreign tax credit is not always straightforward since it depends on what is considered to be foreign tax.

TIMESTAMPS:
0:00 INTRO
0:20 Federal taxes in Canada for US expats
1:45 Defined taxes for US expats in Canada
2:45  US tax on Canadian returns
4:05 OUTRO




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DERREN JOSEPH:
For us Expats living in Canada. What W-Tax W2. So this will be the this is as they pay as you earn taxes in, in the US. So the W2 taxes paid qualifies for the Foreign tax credit calculations. So they went on to say federal income tax withheld, social security taxes, withheld, I know Medicare taxes withheld in the US. Would that qualify for the Foreign tax credit calculations on the Canadian Returns?

BALCHANDER PUDUKKOTAI:
As a matter of fact, yes, it would qualify for it because what happens is you pay your filing, your US tax filings, and then when we actually file the Canadian taxes right here, we do have to consider the taxes paid. And within that, we look at the W2. But, what the, what c r has done right now is they don't, there was a time when we would just take the tax return because of the timing of it, we would take the W2 provided by our clients and we would file the Canadian tax return based on the information on w2. They come back to us and say, no, we actually wanna see the tax return that has been filed to actually know the total amount, the actual tax that has been paid in the US for the US, for the US to give the Foreign tax credit. So it becomes a circular calculation because of its timing of it. So invariably what happens is, I tell my clients that you're providing this information, but we informed them that six months down the road you're going to get a notice of assessment that is going to change these numbers because of the new information that they, they will be getting. Okay. Kul. Any add?

KUL MAKKAR:
Sure. Well, I think, you know, c looks at how the tax term taxes is defined in, in, in the US So the definition does cover, I think Medicare and the other taxes you mentioned. Sometimes there is, and I have a phrase that was a question in the past as well, where the state taxes sometimes c a push back saying that the state tax that you pay would not be given a Foreign tax credit because that's not defined within the definition of Canadian. Then, taxes the way it is being defined within the treaty. So, but you know, mostly I have seen that these are accepted for Foreign tax credit purposes. But yes, as Bal said, it is not what is there on W2 what you file in your tax return would eventually be considered by Canada.



#canada #CanadaExpats #taxesCanada #investors #offshorecitizen #nomadcapitalist  #flagtheory #InternationalEntrepreneur #irs #offshorebanking #ibc #offshorecompany

[ Offshore Tax ] Foreign Tax Credits of US tax on Canadian returns.

Claiming a foreign tax credit is the primary way Canadian residents can avoid paying double tax on foreign income. Still, the ability to claim a foreign tax credit is not always straightforward since it depends on what is considered to be foreign tax.

TIMESTAMPS:
0:00 INTRO
0:20 Federal taxes in Canada for US expats
1:45 Defined taxes for US expats in Canada
2:45 US tax on Canadian returns
4:05 OUTRO




------------------------------------------------

OUR CHANNEL OFFERS:
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YouTube Video VVVRTDRWUGxzSTJKZXdnSHpyeG82SE13LjV2S2pLLW1XQmpr

[ Offshore Tax ] Foreign Tax Credits of US tax on Canadian returns.

January 30, 2023 10:33 pm

[ Offshore Tax ] Taxes for Canadians working in the US.

Aside from visa status, another factor affecting your U.S. tax obligation is your length of stay within a country. The Internal Revenue Service uses the Substantial Presence Test (SPT) to determine whether a Canadian ex-pat qualifies as a non-resident or resident for tax purposes. What does this mean for you? Even if you have a nonimmigrant visa, you may be considered a U.S. resident for tax purposes if you meet the Substantial Presence Test. That means the same tax rules that apply to U.S. citizens and permanent residents also cover you.

TIMESTAMPS:
0:00 INTRO
0:20 Taxes for Canadians working in the US.
1:20 Income taxes in the USA.
2:10 How it triggered tax in the US
2:55 OUTRO



------------------------------------------------

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DERREN JOSEPH:
If I'm a Canadian who's working temporarily in the US, what tax planning should I be doing? That's a very general question, but just general points, gentlemen,

BALCHANDER PUDUKKOTAI:
I, I think we are kind of limited to the best of my knowledge because first of all, you're there temporarily, so you're not having a clean break. So the tax would be filed on a, being a Canadian resident, then I'm not sure, like in the US probably they're filing tax on the earnings in the US not on the worldwide income because they don't have the green card. So then you make use of the foreign tax credit mechanism and try to minimize the Taxes between the two. But I'll ask Kul to add a lot more to this one. 

KUL MAKKAR:
Yeah, in fact, I'd be, you know, I'd be more comfortable if I know what kind of, what source of income are we discussing here? Is it an employment income, business income, or some kind of passive income? But, yes, you know, all that I would want to suggest here is that if it is possible, based on your facts and circumstances, the income that you earn in the US doesn't come back and get taxed again in Canada at a higher rate. If you can avoid that, that would be, you know, the best thing. Although again, as we discussed, and answered in the first question, there are factors that are not easier to kind of comply with. But, you know, the tax planning, again, this is, this is definitely a very wide question and, you know, commenting on it means I will be possible, but you know, as Paula said, there are a few things that you can do based on whatever we know about this question.

BALCHANDER PUDUKKOTAI:
See, what I find is conceptually at the top level, we know the answers from what the tax rules are and conceptually what we can do, and what we cannot do. But the devil is in the detail as we keep digging through and then you go, oh, this doesn't make sense. This is not, it does not qualify and doesn't meet the condition. That's where I think the facts become very, very critical. So I'm sure you know that Derren, that's how it works.


#canada #CanadaExpats #taxesCanada #investors #offshorecitizen #nomadcapitalist  #flagtheory #InternationalEntrepreneur #irs #offshorebanking #ibc #offshorecompany

[ Offshore Tax ] Taxes for Canadians working in the US.

Aside from visa status, another factor affecting your U.S. tax obligation is your length of stay within a country. The Internal Revenue Service uses the Substantial Presence Test (SPT) to determine whether a Canadian ex-pat qualifies as a non-resident or resident for tax purposes. What does this mean for you? Even if you have a nonimmigrant visa, you may be considered a U.S. resident for tax purposes if you meet the Substantial Presence Test. That means the same tax rules that apply to U.S. citizens and permanent residents also cover you.

TIMESTAMPS:
0:00 INTRO
0:20 Taxes for Canadians working in the US.
1:20 Income taxes in the USA.
2:10 How it triggered tax in the US
2:55 OUTRO



------------------------------------------------

OUR CHANNEL OFFERS:
- Updated daily, we help 6, 7, and 8-figure International Entrepreneurs, Expats, Digital Nomads, and Investors legally minimize their global tax burden and protect their wealth.
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YouTube Video VVVRTDRWUGxzSTJKZXdnSHpyeG82SE13LmR3OWhaYW05OGFN

[ Offshore Tax ] Taxes for Canadians working in the US.

January 29, 2023 6:39 pm