DAmico Family Wealth Management Group Of RBC Dominion
D'Amico Family Wealth Management Group Of RBC Dominion Securities Presents Shlomi Levy from Levy Salis LLP “Update on US Tax reform: what does this mean for Canadians” Angelo D’Amico FCSI, CIM, CPA, CMA, CGA, CSWP Vice President - Portfolio Manager Christiana Kavadas B. Comm. Associate Tel: (514) 878 -5196 Email: angelo. damico@rbc. com Tel: (514) 878 -5056 Email: christiana. kavadas@rbc. com Dario Falso Associate Tel: (514) 878 -5049 Email: dario. falso@rbc. com Web : http: //www. damicofamilywealthmanagementgroup. ca February 7 th, 2018 Daniel Marro Marketing Assistant daniel. marro@rbc. com
AVOCATS & NOTAIRES | ATTORNEYS & NOTARIES WWW. LEVYSALIS. COM Update on US Tax Reform What Does What This Mean for Canadians? February 7, 2018 SHLOMI STEVE LEVY BA, LL. B, JD, TEP Attorney/Partner Member of the Québec Bar, Member of the Law Society of Upper Canada (L 3) & Canadian Legal Counsel 2 MONTREAL | FT LAUDERDALE | TORONTO | TEL AVIV
AVOCATS & NOTAIRES | ATTORNEYS & NOTARIES WWW. LEVYSALIS. COM AGENDA • Introduction • Our expertise • Presentation of the Tax Cuts and Jobs Act • Focus on the changes to the US tax system • Highlight what remains the same • Questions 3 MONTREAL | FT LAUDERDALE | TORONTO | TEL AVIV
AVOCATS & NOTAIRES | ATTORNEYS & NOTARIES WWW. LEVYSALIS. COM MONTREAL | FT LAUDERDALE | TORONTO | TEL AVIV 4
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AVOCATS & NOTAIRES | ATTORNEYS & NOTARIES WWW. LEVYSALIS. COM OUR EXPERTISE • • US Real Estate Cross Border Tax and Estate Planning Canadian Estate Planning (Trusts, Wills and POAs) Corporate Tax Planning (Reorgs & Estate Freezes) Moving to the US (Pre-Immigration Tax Planning) Americans Living in Canada Renouncing US Citizenship 6 MONTREAL | FT LAUDERDALE | TORONTO | TEL AVIV
AVOCATS & NOTAIRES | ATTORNEYS & NOTARIES WWW. LEVYSALIS. COM OVERVIEW – THE TAX CUTS AND JOBS ACT (TCJA) • Signed into law on December 22, 2017 by President Donald J. Trump • Cuts individual tax rates on a temporary basis • Changes in deductions available to individuals • Cuts corporate tax rates permanently • Substantially changes the corporate tax regime in the United States • Changes to the tax treatment of the sale of certain partnership interests by non-resident partners • Temporary increase in the US Estate Tax lifetime exemption amount 7 MONTREAL | FT LAUDERDALE | TORONTO | TEL AVIV
AVOCATS & NOTAIRES | ATTORNEYS & NOTARIES WWW. LEVYSALIS. COM THE TCJA – CHANGES TO INDIVIDUAL TAX RATES • The TJCA maintains 7 tax brackets, but introduces new brackets which cut individual tax rates for all income groups • These changes are temporary. They came into effect on January 1, 2018 and expire on December 31, 2025 • New legislation will be required to extend the tax cuts beyond 2025 • Under the TCJA, the highest individual income tax rate is 37% and the threshold is $500, 000 for single filers and $600, 000 for married joint filers • Before the TJCA, the highest individual income tax rate was 39. 6% and the threshold was $418, 400 for single filers and $470, 700 for married joint filers • The Alternative Minimum Tax (“AMT”) exemptions and thresholds are increased • Single filers: exemption of $70, 300 and phase-out of exemption at $500, 000 • Married joint filers: exemption of $109, 400 and phase-out of exemption at $1, 000 8 MONTREAL | FT LAUDERDALE | TORONTO | TEL AVIV
AVOCATS & NOTAIRES | ATTORNEYS & NOTARIES WWW. LEVYSALIS. COM THE TCJA – CHANGES TO INDIVIDUAL TAX RATES • Individuals who do business through entities that are taxed on a pass-through basis may qualify for a 20% deduction on “qualified business income” (QBI) • Sole proprietorships, S-Corporations, Limited Liability Companies (“LLC”), Limited Partnerships (“LP”) • Domestic Business Income only • Includes rental and royalty income • Excludes interest, capital gains, commodities • Excludes specified services business (e. g. health, law, accounting, financial and brokerage services) • Top marginal rate of 29. 6% • Only in effect until December 31, 2025 9 MONTREAL | FT LAUDERDALE | TORONTO | TEL AVIV
AVOCATS & NOTAIRES | ATTORNEYS & NOTARIES WWW. LEVYSALIS. COM THE TCJA – CHANGES TO INDIVIDUAL TAX RATES • The deduction on QBI is limited to the lesser of: 1. 20% of QBI; 2. 50% of the taxpayer’s share of wages paid by the pass-through entity; or • This is subject to a wage threshold of $315, 000 USD for married joint filers and $157, 500 USD for single filers 3. 25% of the taxpayer’s share of wages paid by the pass-through entity and 2. 5% of the unadjusted basis of all qualified property • Qualified property: any tangible property, subject to depreciation, which is held by the business at the end of the year and is used in the production of QBI • Unadjusted basis: Depreciation is not taken into account 10 MONTREAL | FT LAUDERDALE | TORONTO | TEL AVIV
AVOCATS & NOTAIRES | ATTORNEYS & NOTARIES WWW. LEVYSALIS. COM THE TCJA – QBI DEDUCTION FOR CANADIANS • How can Canadians with US businesses take advantage of the deduction for QBI? • Avoid LLCs, Limited Liability Partnerships (LLPs) and Limited Liability Limited Partnerships (LLLPs) • Usable for LPs and S-Corporations that elect to be treated on a pass-through basis • Canadians who own an interest in a US pass-through entity that has employees can claim a deduction under the lesser of the three following headings • 20% of QBI • 50% of wages • 25% of wages plus 2. 5% of the unadjusted basis of qualified property • Canadians who operate rental properties through pass-through entities will generally have limited use of this deduction because these entities often do not have employees. The deduction will be limited to 2. 5% of the unadjusted basis of the property 11 MONTREAL | FT LAUDERDALE | TORONTO | TEL AVIV
AVOCATS & NOTAIRES | ATTORNEYS & NOTARIES WWW. LEVYSALIS. COM THE TCJA – CHANGES TO DEDUCTIONS FOR INDIVIDUALS • The Standard Deductions are nearly doubled • Individuals: from $6, 300 in 2017 to $12, 000 in 2018 • Married joint filers: from $12, 600 in 2017 to $24, 000 in 2018 • The Personal Exemption (which was $4, 050 in 2017) is suspended • The TCJA limits deductions for state and local taxes to a fixed amount of $10, 000 • Before the TCJA, these taxes were deductible regardless of the amount • The mortgage interest deduction is limited to payments on debt in the amount of $750, 000 for mortgages that originated after December 31, 2017 • Before the TCJA, interest payments could be deducted for debt of up to $1. 1 million • The home equity loan interest deduction is suspended • Note: All changes to deductions are only in effect until December 31, 2025 12 MONTREAL | FT LAUDERDALE | TORONTO | TEL AVIV
AVOCATS & NOTAIRES | ATTORNEYS & NOTARIES WWW. LEVYSALIS. COM THE TCJA – HOW THE CHANGES IN DEDUCTIONS FOR INDIVIDUALS APPLY TO CANADIANS • Canadians with US situs assets or investments are affected by the following changes: • The suspension of the Personal Exemption (which was $4, 050 in 2017) • The limitation of state and local taxes to $10, 000 • The following changes apply only to US citizens and US Green Card holders • The doubling of the Standard Deductions • The limitation of the mortgage interest deduction to payments on debt in the amount of $750, 000 for mortgages that originated after December 31, 2017 13 • The suspension of the home equity loan interest deduction MONTREAL | FT LAUDERDALE | TORONTO | TEL AVIV
AVOCATS & NOTAIRES | ATTORNEYS & NOTARIES WWW. LEVYSALIS. COM THE TCJA – CORPORATE TAX CUT • The TCJA created a flat corporate tax rate of 21% • The flat corporate tax rate replaces the marginal corporate tax rates. Before the TCJA, the highest corporate tax rate was 35% and the threshold was $100, 000 • The TCJA repeals the corporate AMT • Unlike the individual income tax cuts, the corporate tax cut is permanent • Although the corporate tax cut makes C-Corporations a less taxing vehicle for Canadians to invest in the United States or for owning US real estate, state corporate tax and taxation of dividends may make C-Corporations a less tax efficient vehicle than LPs for Canadians 14 MONTREAL | FT LAUDERDALE | TORONTO | TEL AVIV
AVOCATS & NOTAIRES | ATTORNEYS & NOTARIES WWW. LEVYSALIS. COM THE TCJA – CHOICE OF ENTITY FOR CANADIANS TO DO BUSINESS IN THE UNITED STATES US and Canadian taxation of US corporations • US corporate tax rate: 21% • State tax rates vary from state to state. Florida levies a 5. 5% corporate tax on corporate profits. • Dividend withholding tax or branch profits tax of 5% • Before Canadian tax is owed on the distributed dividends, the combined US and State tax rate is already greater than the Canadian corporate tax • Canadian dividend tax at the applicable marginal rate 15 MONTREAL | FT LAUDERDALE | TORONTO | TEL AVIV
AVOCATS & NOTAIRES | ATTORNEYS & NOTARIES WWW. LEVYSALIS. COM THE TCJA – CHOICE OF ENTITY FOR CANADIANS TO DO BUSINESS IN THE UNITED STATES • A Quebec resident operates a USCo in Florida through his Canadian Hold. Co • USCo generates $150, 000 USD in profits • USCo pays the following tax in the US: • Florida state tax: $8, 250 • US federal tax: $29, 767. 50 • Dividend withholding tax: $5, 599. 13 • Total US tax: $43, 616. 63 USD • Remaining profits: $106, 383. 37 USD • If the USD and the CAD were at parity, the Canadian dividend tax rate would be 31. 77% • CAD tax: $33, 798 USD • Total US/CAD tax: $77, 414. 63 USD • Remaining profits: $72, 585. 37 USD • The effective US/CAD tax rate is 51. 61% 16 MONTREAL | FT LAUDERDALE | TORONTO | TEL AVIV
AVOCATS & NOTAIRES | ATTORNEYS & NOTARIES WWW. LEVYSALIS. COM THE TCJA – CHOICE OF ENTITY FOR CANADIANS TO DO BUSINESS IN THE UNITED STATES Pass-through entities • LLCs, LLPs and LLLPs still remain problematic for Canadians due to their treatment as corporations by the CRA: mismatch in tax credits • LPs remain slightly preferable to corporations for two reasons: • Disregarded entities in both the US and Canada • No dividend taxation • Matching tax credits • Availability of the deduction for qualified business income if the LP has employees or uses depreciable assets to generate income 17 MONTREAL | FT LAUDERDALE | TORONTO | TEL AVIV
AVOCATS & NOTAIRES | ATTORNEYS & NOTARIES WWW. LEVYSALIS. COM THE TCJA – CHOICE OF ENTITY FOR CANADIANS TO DO BUSINESS IN THE UNITED STATES • A Canadian operates a US LP in a State with an individual tax rate of 5% and he is the 99. 5% limited partner • The LP pays out $200, 000 USD in wages • The LP generates $150, 000 USD in profits • He owes the following US tax: • State tax: $7, 462. 50 • US federal tax (28%): $39, 700. 50 • QBI deduction: 150, 000 × 20% = $30, 000 • Total US tax: $17, 163 USD • Remaining profits: $132, 867 USD • If the USD and the CAD were at parity, the applicable tax rate on these profits would be 49. 97% with a tax credit for US tax paid 18 MONTREAL | FT LAUDERDALE | TORONTO | TEL AVIV
AVOCATS & NOTAIRES | ATTORNEYS & NOTARIES WWW. LEVYSALIS. COM THE TCJA – CHANGES TO DEDUCTIONS AVAILABLE TO CORPORATIONS • Business interest deduction is capped at 30% of business income (excluding depreciation) • Section 179 small business expense deductions are no longer capped at $500, 000. Instead, a 100% deduction may be claimed for new and used property acquired after September 27, 2017 • Net operating losses (“NOL”) are limited to 80% of taxable income • NOL can no longer be carried back and may be carried forward indefinitely • Both Canadians and Americans need to watch out for a mismatch on depreciation 19 MONTREAL | FT LAUDERDALE | TORONTO | TEL AVIV
AVOCATS & NOTAIRES | ATTORNEYS & NOTARIES WWW. LEVYSALIS. COM THE TCJA – FUNDAMENTAL CHANGES TO US CORPORATE TAX REGIME • Under the TCJA, US corporations are no longer taxed on their worldwide income. Instead, they are primarily taxed on US sourced income, subject to a one-time expatriation tax on foreign-sourced earnings and profits and GILTI • Changes to Controlled Foreign Corporation (“CFC”) rules • Expansion of US shareholders subject to CFC rules • One-time repatriation tax on foreign-sourced earnings and profits (“E&P”) • Introduction of Global Intangible Low-Taxed Income (“GILTI”) • Introduction of Foreign Derived Intangible Income (“FDII”) • Note: These changes primarily concern US citizens and US Green Card holders, including Americans living in Canada. 20 MONTREAL | FT LAUDERDALE | TORONTO | TEL AVIV
AVOCATS & NOTAIRES | ATTORNEYS & NOTARIES WWW. LEVYSALIS. COM THE TCJA – EXPANSION OF SHAREHOLDERS SUBJECT TO CFC RULES • Before the TCJA, only a US person who owned 10% of the voting shares of a CFC was subject to CFC rules • CFC: A corporation that is controlled by foreign shareholders • Obligation to report Subpart F income in proportion to US person’s ownership interest in CFC even if the income is not distributed • The TCJA broadens the group of persons subject to CFC rules in 2 ways • The first way: The TCJA expands US shareholder status to include US persons who own 10% of non-voting shares of a CFC 21 MONTREAL | FT LAUDERDALE | TORONTO | TEL AVIV
AVOCATS & NOTAIRES | ATTORNEYS & NOTARIES WWW. LEVYSALIS. COM THE TCJA – EXPANSION OF SHAREHOLDERS SUBJECT TO CFC RULES • The second way: the “downward attribution” rule • Before the TCJA, if a foreign corporation had a US subsidiary and foreign subsidiaries, there was a clear segregation between the US subsidiary and the foreign subsidiaries • The US subsidiary was not deemed to own the shares of stock in the foreign subsidiaries • The TCJA provides for a downward attribution and applies it not only to US corporations, but also to US partnerships and US trusts • Under the downward attribution rule, the US subsidiary is now deemed to own theses shares of stock • Even if a foreign corporation is deemed to be a CFC under the downward attribution rule, Subpart F income from this corporation is included in the income of a US shareholder only if the US shareholder directly or indirectly owns shares of stock in the foreign corporation • This change applies retroactively to January 1, 2017 • We are working with UHY Victor LLP on ascertaining the full scope of how the 22 ONTR E A L | F T L A U D who E R D A L are E | subject T O R O N T Oto | the T E LCFC A V I V rules TCJA expands the. MUS shareholders
AVOCATS & NOTAIRES | ATTORNEYS & NOTARIES WWW. LEVYSALIS. COM THE TCJA – ONE-TIME REPATRIATION TAX ON E&P OF A SFC or CFC • Applies to a US person who is a shareholder of a CFC or a Special Foreign • A SFC is a foreign corporation with at least one US corporate shareholder • A US person who is a shareholder of a CFC or a SFC is deemed to have repatriated post-1986 E&P that are not attributable to effectively connected income of a trade or business in the United States • This is a one-time tax • It may be paid in installments over an 8 year period • Note: This tax applies only to US citizens and Green Card holders. It is a concern for Americans living in Canada • We are working with UHY Victor LLP on ascertaining the full scope of how the repatriation tax will be applied Corporation (“SFC”) 23 MONTREAL | FT LAUDERDALE | TORONTO | TEL AVIV
AVOCATS & NOTAIRES | ATTORNEYS & NOTARIES WWW. LEVYSALIS. COM THE TCJA – ONE-TIME REPATRIATION TAX ON E&P OF A SFC or CFC • The untaxed E&P are taxed at the following rates if the US person is a corporation which was taxed at 35% in 2017: • 15. 5% tax rate for earnings held in cash (e. g. , cash, accounts receivable, commercial paper, certificates of deposit, foreign currency, etc. ) • 8% tax rate for earnings held in non-cash assets • The repatriation tax may be higher if the US person is an individual in the top income tax bracket of 2017, which was 39. 6% • Tax rates if paid in installments • First 5 years: 8% each year • Year 6: 15% • Year 7: 20% • Year 8: 25% • A foreign tax credit in the US may be claimed against the expatriation tax for dividends paid out in 2017 by a Canadian corporation 24 MONTREAL | FT LAUDERDALE | TORONTO | TEL AVIV
AVOCATS & NOTAIRES | ATTORNEYS & NOTARIES WWW. LEVYSALIS. COM THE TCJA – REDUCTION IN “KICK-OUT” TAX RATE FOR A CFC • Before the TCJA, income that would ordinarily be included as Subpart F income is excluded if it was taxed at a sufficiently high foreign tax rate • This rate was 31. 5%, which was equal to 90% of the highest US corporate tax rate • This high foreign tax rate is sometimes called the “kick-out” rate • The TCJA reduces the kick-out rate to 18. 9%, which is equal to 90% of the sole US corporate tax rate of 21% • This affects US citizens who own shares of stock in CFCs • If the CFC operates in a jurisdiction with lower corporate tax rates, the US citizen will be required to include a greater portion of the CFC’s income as Subpart F income 25 MONTREAL | FT LAUDERDALE | TORONTO | TEL AVIV
AVOCATS & NOTAIRES | ATTORNEYS & NOTARIES WWW. LEVYSALIS. COM THE TCJA – GLOBAL INTANGIBLE LOW-TAXED INCOME (“GILTI”) • The TCJA creates a new category of Subpart F income for CFCs, Global Intangible Low-Taxed Income (“GILTI”) • GILTI is the global income of a CFC, reduced for adjustments for Effectively Connected Income (ECI) and other Subpart F income, that exceeds 10% of the CFC’s Qualified Business Asset Investments (QBAI) • QBAI: CFC’s fixed assets that are depreciable as trade or business assets • US shareholders subject to CFC rules must include their proportionate share of a CFC’s GILTI on a current basis • A corporation with GILTI receives a 50% deduction of GILTI and therefore pays an effective tax of 10. 5% on its GILTI • After 2025, the deduction is reduced to 37. 5%. The effective tax rate will be 13. 125% • We are working with UHY Victor LLP on ascertaining the full scope of the application of GILTI to US shareholders of CFCs 26 MONTREAL | FT LAUDERDALE | TORONTO | TEL AVIV
AVOCATS & NOTAIRES | ATTORNEYS & NOTARIES WWW. LEVYSALIS. COM THE TCJA – DEDUCTION FOREIGN DERIVED INTANGIBLE INCOME (“FDII”) • The TCJA creates another category of income, Foreign-Derived Intangible Income (“FDII”) • FDII is income that is attributable to the following: • The sale of property to foreign persons for use, consumption or disposition outside of the United States • Rendering services to any person, or with respect to property, located outside the United States • A US corporation is entitled to a deduction of 37. 5% between 2018 and 2025 for FDII • The effective corporate tax rate on FDII will be 13. 125% • The corporate deduction for FDII will be reduced to 21. 875% in 2026 • The effective corporate tax rate on FDII will be 16. 406% • We are working with UHY Victor LLP on ascertaining the full scope of the application of FDII to US corporations 27 MONTREAL | FT LAUDERDALE | TORONTO | TEL AVIV
AVOCATS & NOTAIRES | ATTORNEYS & NOTARIES WWW. LEVYSALIS. COM THE TCJA – SALE OF CERTAIN PARTNERSHIP INTERESTS BY NON-RESIDENTS • The TCJA provides that gains from a sale of a partnership interest by a non-resident partner are subject to US net income tax to the extent that a partner would be allocated ECI from a sale of the partnership’s assets • The tax applies to transactions on or after November 27, 2017 • The TCJA provides that where a partnership has any ECI-generating assets, a non-resident partner who sells a partnership interest will be subject to a 10% withholding on the gross sale price • The purchaser is responsible for the withholding • The withholding applies only to transactions after December 31, 2017 28 MONTREAL | FT LAUDERDALE | TORONTO | TEL AVIV
AVOCATS & NOTAIRES | ATTORNEYS & NOTARIES WWW. LEVYSALIS. COM THE TCJA – US ESTATE TAX CHANGE • The US Estate Tax lifetime exemption amount is doubled from $5 million (plus inflation) to $10 million (plus inflation) • In 2018, the lifetime exemption amount is $11. 2 million instead of $5. 6 million • The change applies to US citizens, US domiciliaries and Canadians with US situs assets • Married couples can continue to double up on the lifetime exemption amount. It is possible to leave $22. 4 million to a surviving spouse instead of $11. 2 million • These changes are subject to a sunset provision. They are in effect as of January 1, 2018 and expire on December 31, 2025 • If additional legislation is not passed, the US Estate Tax lifetime exemption amount will revert back to $5 million (plus inflation) 29 MONTREAL | FT LAUDERDALE | TORONTO | TEL AVIV
AVOCATS & NOTAIRES | ATTORNEYS & NOTARIES WWW. LEVYSALIS. COM THE TCJA – US ESTATE TAX CHANGE • One unresolved question is the clawback of taxable gifts by US citizens on their combined US Estate Tax and US Gift Tax lifetime exemption. • Example • A US citizen makes a gift in 2018 that exceeds the applicable annual gift tax exemption. • He claims a reduction in his lifetime exemption. • The increase in the lifetime exemption expires in 2026. • He dies in 2027. • In determining the available lifetime exemption at the time of the decedent’s death, will the IRS offset the gift tax based on the lifetime exemption at the time the gift was made or at the time of death? • The IRS will issue regulations on this question 30 MONTREAL | FT LAUDERDALE | TORONTO | TEL AVIV
AVOCATS & NOTAIRES | ATTORNEYS & NOTARIES WWW. LEVYSALIS. COM THE TCJA – US ESTATE TAX PLANNING FOR CANADIANS • Given the increase in the US Estate Tax lifetime exemption, is US Estate Tax planning still an issue for high net worth Canadians with US situs assets, high net worth Canadians with US children or dual US and Canadian citizens? YES • Why? 1. The increase in the US Estate Tax lifetime exemption expires in 2025 and might not be renewed 2. The increase in the US Estate Tax lifetime exemption could also be reversed after the next US presidential election in 2020 31 MONTREAL | FT LAUDERDALE | TORONTO | TEL AVIV
AVOCATS & NOTAIRES | ATTORNEYS & NOTARIES WWW. LEVYSALIS. COM THE TCJA – WHAT HAS NOT CHANGED • Tax rates on capital gains and qualified dividends remain the same • The highest marginal rate remains 20% • The Net Investment Income Tax (“NIIT”) remains in effect at a flat rate of 3. 8% • The maximum aggregate tax rate on capital gains and qualified dividends remains 23. 8% • Gift tax exemption amounts were not changed by the TCJA • $152, 000 for gifts between spouses for 2018 • $15, 000 for gifts to other persons for 2018 and the foreseeable future • The Foreign Account Tax Compliance Act (“FATCA”) remains in effect • The tax regime applicable to the expatriation of US citizens and long-term residents (persons who have had a Green Card for 8 of the last 15 fifteen years) remains the same 32 MONTREAL | FT LAUDERDALE | TORONTO | TEL AVIV
AVOCATS & NOTAIRES | ATTORNEYS & NOTARIES WWW. LEVYSALIS. COM OUR PROCESS Analyze Recommend Implement 514 -940 -8070 WWW. LEVYSALIS. COM 33 MONTREAL | FT LAUDERDALE | TORONTO | TEL AVIV
AVOCATS & NOTAIRES | ATTORNEYS & NOTARIES WWW. LEVYSALIS. COM Questions? Shlomi Steve Levy slevy@levysalis. com 514 -940 -8070 WWW. LEVYSALIS. COM 34 MONTREAL | FT LAUDERDALE | TORONTO | TEL AVIV
AVOCATS & NOTAIRES | ATTORNEYS & NOTARIES Shlomi Steve Levy slevy@levysalis. com 514 -940 -8070 www. levysalis. com MONTREAL | FT LAUDERDALE | TORONTO | TEL AVIV 35
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