Similar Posts


  1. Good to know because I’m applying for work in the US. Anyone need a junior electrical engineer with microwave skills and a masters degree?

  2. @Nick H “…a neat taxation trick which doesn’t seem to bother too many people in Canada.”

    Well, yes. But. The US “exit tax” rules work differently from Canadian ones. For example, the US exit tax doesn’t exempt retirement accounts, but instead demands an instant 30% tax on your entire IRA balance on the day you leave, as if immediately distributed. Potentially retirement-destroying.

  3. If you haven’t been to a Tim Horton’s, you aren’t missing much. The donuts are good, but not great. The coffee is predictably pedestrian and perfectly consistent across all locations. The lasagna is on par with the canned variety from a supermarket. I had no idea this “Canadian” company was incorporated in Delaware. But it’s basically and bizarrely a cultural institution, no doot aboot it, eh.

    Also, “make-pretend sales,” or as the CRA calls them, “deemed dispositions,” really aren’t too bad. In Canada, when you die, you are deemed to dispose of your assets and are liable for capital gains tax. No estate tax. When you immigrate, you are deemed to dispose of and re-aquire your assets at their current value to establish a starting point for Canadian taxation. Likewise on emigration to produce a liability for an “exit tax” by another name.

    Deemed disposition is a neat taxation trick which doesn’t seem to bother too many people in Canada. I don’t think the problems with Subpart F are unique to that part. I think the real problem is that no one is trying to figure out who is actually being taxed on what, and who should be taxed on what transactions.

  4. Perhaps this is the “canary in the coal mine” for the US – Tim Horton’s can now raise capital on the Toronto Stock Exchange without FATCA and the IRS (as long as they don’t take money from “US persons”) – well done.

    I’ve never been to a Tim Horton’s but the menu looks better than Starbucks or Dunkin Donuts (particularly if you want chilli or lasagna bowls).

    I hope other companies will follow the road to Toronto to show Levin and Grassley they’ve f**ked up.

    Good luck Tim Hortons.

  5. Do you think it might be possible to harmonize the expatriation tax rule for individuals with those of corporations. My understanding is that several companies such as Tim Hortons(a Canadian donut/coffee shop) that were technically incorporated in Delaware but whose earnings were predominatly non US were able to sucessfully “expatriate” back to their “home” jurisdictions. I posted a link below to the press conference the Prime Minister of Canada had at Tim Horton’s headquarters in Canada the day they re-incorporated from Delaware to Ontario.

Comments are closed.

Tax laws change over time, and the information in this post above may be less accurate today than it was at the time of the last revision. This post is not tax advice for your specific situation. Please contact an international tax professional to get personalized advice for your situation.