Tax Trends
Understanding the U.S. Days Counting Test and U.S. Tax Residency
In most countries an individual’s tax residency is determined by their residential ties, which considers one’s own…
IRS Announces the end of the Offshore Voluntary Disclosure Program though Streamlined is still around – for now
On March 13, 2018 the Internal Revenue Service announced (IR-2018-52) that it will close the 2014 Offshore…
The importance of E&P – Will you be paying the right amount of tax to the IRS?
An accurate determination of “earnings and profits” (E&P) of a foreign (i.e., Canadian) corporation is often an…
IRS Form 5472 : An easy but expensive filing obligation to overlook?
Recent media coverage, as it relates to U.S. tax in Canada, has almost entirely focused on the…
Understanding Constructive Share Ownership
The Tax Cut and Jobs Act (TCJA) has significant implications for United States persons who own shares…
Changes to U.S. “Kiddie Tax” Rules
With both the increases in Canadian personal tax rates, over the last few years, and the new…
Do You Owe Money to the IRS? You May Lose Your US Passport
If you are a U.S. citizen and you have a “seriously delinquent tax debt” with the IRS,…
Are you GILTI? New U.S. Rules Impact U.S. Individual Shareholders of Canadian Corporations
“An Act to provide for reconciliation pursuant to titles II and V of the concurrent resolution on…
U.S. Tax Reform – Deemed Repatriation Tax and Individual Shareholders of Canadian Corporations
On December 22, 2017 President Trump signed into law, “An Act to provide for reconciliation pursuant to…
U.S. Corporate Tax Reduction – Impact on CCPC shareholders – Part II (GRIP)
This U.S. Tax Tip follows up on the US Tax Tip issued on November 30, 2017. The facts/assumptions…
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STEP CANADA/CRA Roundtables
Trusts and International Tax Treaties
Taxation of Real Estate in Canada
Towards Greater Fairness in Taxation: A Model Taxpayer Charter
Taxation of Trusts and Estates: A Practitioner’s Guide 2024
Taxation at Death: A Practitioner’s Guide, 2021
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