Tax Law and International Tax Law

The Internal Revenue Service is preparing to roll out a substantially revised Criminal Voluntary Disclosure Program (VDP), and the headline change is a lower penalty bill for taxpayers who come forward.

The US Court of Federal Claims recently addressed a critical question for Canadian exempt organizations earning US-source income: can they rely on fiscal transparency rules to claim treaty benefits through investment vehicles? The court's ruling in The South Saskatchewan Community Foundation Inc. v. United States examines when charitable organizations may look through intermediary entities to access tax exemptions under the US-Canada tax treaty, with significant implications for cross-border investment

The Treasury Department and IRS have released proposed regulations that would revoke Section 501(c)(3) tax-exempt status for private schools engaging in race-based admissions or diversity programs, fundamentally reshaping how educational institutions approach affirmative action and DEI initiatives.