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U.S. International Tax Issues for Individuals

November 17, 2022

When looking at US tax filings, domestic rules of the first country with the right to tax an income item is looked at first before turning to any tax treaty benefits and any underlying treaty “savings clause” when a second country is involved.  Remember not every country has a treaty with Canada.  The U.S.-Canada Treaty benefits being claimed must disclosed in a US tax filing.  Tie-breaker provisions for residency may not relieve FBAR filing requirements under a different section of the U.S. tax code.  See this article for other points of note.

US clients with international tax issues: Five helpful tips (

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