The U.S. Repatriation Tax – IRC §965: Proposed Regulations Issued

On August 3, 2018 the IRS issued “final” proposed regulations implementing new section 965 of the Internal…

FBAR Penalties – the Court Speaks (for now)

The Internal Revenue Service was handed a defeat with respect to its ability to assess some penalties…

IRS Service Offerings – Available to Some, Not All

U.S. citizens abroad are burdened with the same federal tax compliance obligations as U.S. residents.  In fact,…

U.S. Sales Tax – Update: The Streamlined Sales and Use Tax Agreement (SSUTA)

In light of the United States Supreme Court South Dakota v. Wayfair et al decision, 585 U.S.__(2018)   (see U.S. Tax…

The U.S. Repatriation Tax – IRS issues further guidance

On June 4, 2018 the IRS issued News Release IR-2018-131.  In this release the IRS address some…

New IRS Compliance Programs

On July 2nd, the IRS Large Business and International division (LB&I) announced five new additional compliance programs.  …

Wayfair, you’re just what I don’t need South Dakota v. Wayfair, Inc. et al Major Changes Coming for U.S. Sales Tax

As Canadian companies grow their business into the United States one area of planning that is often…

What is my U.S. taxable year (as it relates to certain Canadian corporations)?

The recently enacted U.S. Tax Cuts and Jobs Act introduced new IRC §965, “Treatment of Deferred Foreign…

IRS Provides Some Relief For U.S. Taxpayers Abroad in Meeting the Repatriation Tax Payment Deadlines

Yesterday, April 2, 2018, the IRS released Notice 2018-26, the long-awaited additional guidance related to the one-time…

Understanding U.S. Due Dates, Extensions and Payment Dates

The due date for a U.S. personal income tax return will depend on both the residence of…

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Taxation of Real Estate in Canada

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Towards Greater Fairness in Taxation: A Model Taxpayer Charter

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Taxation at Death: A Practitioner’s Guide, 2021

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