Practice Areas

Practising US tax law out of Canada has both its challenges and opportunities. Alexey Manasuev’s practice areas include treaty planning, US tax and cross-border tax consulting for businesses and individuals, assistance in IRS audits and representation of clients on Appeals, assistance in identifying procedural alternatives for becoming US tax-compliant, estate and gift tax planning, and other areas.

Compliance is no longer an option

According to Forbes.com, no group is more severely impacted than US persons living abroad. US persons, in this sense, not only include US citizens or green card holders, but anyone who is treated as a US resident for US federal income tax purposes, a determination which may not be the easiest, or most self-evident one, to make.

For those living and working in foreign countries, it is almost a given that they must report and pay tax where they live. But they also continue to be required to file tax returns in the United States – one of only three countries in the world that taxes its citizens and residents on a worldwide basis. What’s more, U.S. reporting is based on US persons’ worldwide income, even though they are paying taxes in the country in which they live.

^[i] And of note for those in Canada, in February, 2014, Canada and the U.S. signed a Model I Intergovernmental Agreement (“IGA”) under Foreign Account Tax Compliance Act (“FATCA”) to ensure that they work jointly to prevent tax evasion by significantly enhancing their information exchange and collection efforts,[ii] making voluntary compliance a smart move for everyone.

Tax Treaty Planning

Understanding the applicable provisions of the Canada-US income tax treaty, other applicable US income tax treaties, and the ability to take advantage of favorable provisions under particular taxpayers\' facts and circumstances is critical to successful management of one\'s tax exposure

IRS Offshore Voluntary Disclosure Program (OVDP) Assistance

The ongoing IRS enforcement and compliance initiatives, enhanced cooperation between the IRS and the CRA, as well as other tax authorities, ever increasing transparency

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Foreign Account Tax Compliance Act (FATCA) Compliance

Foreign Account Tax Compliance Act of 2010 (\"FATCA\") dramatically changed the compliance landscape and significantly curtailed the ability of US persons to conceal their foreign financial assets and

Streamlined Filing Compliance Procedures (SFCP) Assistance

In 2014, the IRS made significant changes to its amnesty programs and introduced two simplified procedures for those delinquent taxpayers who did not willfully fail to file their US tax returns and disclose their foreign financial

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Passive Foreign Investment Company (PFIC) Planning

The United States has several anti-deferral regimes that apply to US persons who have business interests or investments outside of the United States. One of such anti-deferral regimes is what is called Passive Foreign Investment Company

US Cross-Border Tax Planning & Structuring for Businesses

Expanding into the United States, structuring US operations or being engaged in M&A activity requires a lot of work, including advice on tax-efficient structuring and how to effectively manage US tax exposure. There are a lot of non-tax considerations

U.S. Trade or Business and Permanent Establishment Planning

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Financing of U.S. and non-U.S. operations

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