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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
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
3
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
4
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
5
"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
6
Baby, There's High Tax Rates Outside
I really can't stay (but baby there's high tax rates outside).
Canada
27 Dec 2018
7
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
8
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
9
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
10
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
11
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
12
Important Changes To US Tax Filing Deadlines For Canadians
Under prior law, the filing deadline for US corporations (that is, corporations subject to the US corporate income tax), was the fifteenth day of the third month following the end of the taxable year.
Canada
25 Aug 2015
13
US Proposes Relief For Some Who Renounce US Citizenship: Is FATCA A Motivating Factor?
On February 2, 2015 the Obama Administration acknowledged the plight of certain US citizens residing abroad and proposed limited relief.
Canada
12 Feb 2015
14
Problems With New IRS Procedures For Canadian Retirement Plans
Revenue Procedure 2014-55 purports to make US tax filing easier for US citizens or residents who own Canadian Registered Retirement Savings Plans.
Canada
15 Oct 2014
15
In FATCA-Land, A Canadian Trust Is A Bank
When Alice found herself in Wonderland, she observed a recognizable world that had been turned on its side.
Canada
11 Feb 2014
16
Beware Of The US "Snowbird Visa TAX BOMB!"
The current immigration bill pending before the US Congress contains provisions that will make it easier for Canadians and retirees to obtain non-immigrant status in the US.
Canada
16 May 2013
17
IRS Offers Partial Tax Amnesty For Canadians With "Low Compliance Risk," Though Questions Remain
On June 26, 2012 the IRS announced new procedures that will enable non-resident US taxpayers who demonstrate "low compliance risk" to bring unfiled tax returns and related tax reporting obligations current and avoid potentially ruinous penalties.
Canada
4 Jul 2012
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