U.S. source-of-interest rules, part one: how the U.S. does residence-based taxation (very badly, with lots of traps)

Image of CN Tower

The firm which designed the CN Tower couldn’t get correct U.S. tax advice. What do you think your chances are on a ground-floor budget? (Photo: Local Hero/Wikimedia Commons)

On Twitter, Andrew Grossman mentioned Housden v. Commissioner, 63 T.C.M. 2063 (1992). Mr. Housden, a partner of

FULL ARTICLE http://isaacbrocksociety.ca/2017/05/22/u-s-source-of-interest-rules-part-one-how-the-u-s-does-residence-based-taxation-very-badly-with-lots-of-traps/


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