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1
CaseNotes For October, 2019
These include circumstances where there is a high degree of non-compliance risk, uncertainty or large tax reserves.
Canada
16 Oct 2019
2
Frozen Bank Accounts Of US Citizens In Europe – What Does It Mean For Canada
French and British banks are looking for ways to comply with a 2010 US law known as the Foreign Account Tax Compliance Act
Canada
9 Sep 2019
3
Case Notes For July, 2019
Section 116 of the Act provides rules that protect the Canadian government's ability to collect tax on capital gains on a disposition of "taxable Canadian property".
Canada
11 Jul 2019
4
2019 STEP Canada CRA Roundtable
On Friday June 7, 2019, the Canada Revenue Agency ("CRA") Roundtable of the annual STEP Canada National Conference was held.
Canada
11 Jul 2019
5
Introducing CaseNotes
As tax practitioners, a good chunk of our careers are spent keeping up-to-date on changes in tax law. Changes can arise from legislative amendments, case law that helps to interpret complex
Canada
7 Jun 2019
6
"Mummy, Am I An American?" A Tax Nightmare, In One Act
Figuring out whether you are an American citizen can bring with it some incredibly complex and onerous tax surprises.
United States
28 May 2019
7
Baby, There's High Tax Rates Outside
I really can't stay (but baby there's high tax rates outside).
Canada
27 Dec 2018
8
Canadians Owning U.S. Vacation Property After 2018 U.S. Estate Tax Changes
By now most Canadians are aware that the 2017 U.S. tax reform bill increased the estate tax basic exclusion amount under IRC 2010(c)(3) from US $5m (US $5.49m for 2017) to US $10m ...
Canada
18 Jan 2018
9
Our Firm's Correspondence To The Minister Of Finance: Round 2
Ever since the release of the July 18, 2017 private corporation tax proposals by the Canadian government, our firm has been very active in studying the proposals and informing the public of the consequences...
Canada
18 Sep 2017
10
Meeting Your US Filing Obligations In 6 Steps:
Are you a US citizen living abroad? Did you know that the US taxes on both citizenship and residency? If you're a US citizen, you are required to file yearly tax returns with the IRS – even if you don't live on US soil.
Canada
21 Jul 2017
11
Are You A US Citizen With An Australian Mortgage? Beware Of A Potentially Nasty Tax Surprise!
US citizens residing outside the United States may find that they owe US tax when they've borrowed local currency to finance a primary residence
United States
10 Jul 2017
12
New Individual Tax Identification Renewal Rules
The IRS started to accept 2016 individual tax returns on January 23, 2017. A nonresident alien individual must renew his or her Individual Taxpayer Identification Number (ITIN) in order to file...
Canada
5 Jun 2017
13
Federal Budget 2017 - Proposed Amendments To Taxation Of Work In Progress ("WIP") For Professionals
The 2017 Federal Budget contains a proposal to repeal section 34 of the Income Tax Act (the "Act").
Canada
5 Jun 2017
14
International Estate Planning After US Tax Reform
During the 2016 U.S. presidential campaign then candidate Donald J. Trump and the Republican National Committee ("RNC") outlined similar plans to repeal the U.S. estate and gift tax regimes.
Canada
3 May 2017
15
US Citizens Living In Australia – US Tax Filing Obligations
On July 4, 2015, The Sydney Morning Herald ran an article entitled "Why Australia is now home to the sixth largest American population in the world."
United States
22 Jul 2016
16
Canadian Decedents With US Real Estate
On July 31, 2015, the United States' Surface Transportation and Veterans Health Care Choice Improvement Act of 2015 added new Code sections 1014(f) and 6035. On March 2, 2016, the IRS released related regulations.
Canada
3 Jun 2016
17
Fort McMurray Fires – Alberta Strong
This morning, Albertans woke up to an assessment of the damage that has been inflicted on the city of Fort McMurray.
Canada
5 May 2016
18
FATCA In Canada: The "Cure" For A U.S. Place Of Birth
This paper provides analysis of one of the foundational elements of the Foreign Account Tax Compliance Act (FATCA) and various intergovernmental agreements (IGAs)...
Canada
4 Nov 2015
19
Canadian Challenge To FATCA
In its 2015 budget, the federal government announced a commitment to implement the OECD's common reporting standards starting in July 2017 and reaffirmed Canada's commitment to introduce draft legislation in 2015.
Canada
4 Nov 2015
20
Decision In Canadian Challenge To FATCA Expected Soon
The Canadian Federal Court heard oral arguments on August 4 and 5 in a lawsuit that challenges the law that implements the intergovernmental agreement between Canada and the U.S. relating to the Foreign Account Tax Compliance Act.
Canada
1 Sep 2015
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