North America: Tax

The perception that Internal Revenue Service enforcement is stronger than Canada Revenue Agency enforcement is common among taxpayers and advisors, particularly in cross-border contexts.

Permanent establishment Canada analysis has become increasingly complex due to the OECD’s 2025 remote work guidance. Remote work permanent establishment Canada risk is now a central concern for businesses operating across borders and provinces.

Indirect tax obligations are evolving rapidly as governments modernize their rules for the digital economy. If your organization is working across borders...

Section 160 of the Income Tax Act (ITA) is one of the most potent collection tools available to the Canada Revenue Agency (CRA). While most tax liabilities are personal to the individual who earned the income, section 160 creates a form of “derivative” or secondary liability.

Real property owners in Canada should be aware that their tax obligations may differ depending on whether a property is used for residential (such as renting as a home or apartment) or for commercial purposes (such as renting for business use).

The Dominican Republic has emerged as a prime destination for international real estate investment, supported by comprehensive legal protections, fiscal incentives including 15-year property tax exemptions, and modernized digital infrastructure. Legal experts highlight how the combination of macroeconomic stability, transparent regulatory frameworks, and unrestricted capital repatriation has positioned the country as one of the Caribbean's most competitive and reliable real estate markets.

When the Canada Revenue Agency’s tax auditors can’t rely on your official books and records—whether it’s because they’re incomplete, disorganized, or non-existent—they don’t just shrug and move on.

Foreign exchange bureaus operating in Canada are subject to a comprehensive compliance regime under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act, administered primarily by the Financial Transactions and Reports Analysis Centre of Canada, alongside tax reporting obligations enforced by the Canada Revenue Agency.

Cross-border taxpayers, corporations, investors, and high-net-worth individuals increasingly face scrutiny from both the Canada Revenue Agency (CRA) and the Internal Revenue Service (IRS).

Transfer pricing complexities emerge as artificial intelligence systems increasingly rely on vast training datasets, raising critical questions about how multinational corporations should value and allocate these intangible assets across jurisdictions. The intersection of AI development and international tax law presents novel challenges for determining arm's length pricing when data crosses borders within corporate structures.

Navigate the complexities of Canadian transfer pricing audits with expert guidance on documentation requirements, CRA audit powers, and privilege protection. Learn strategic approaches to functional interviews, information requests, and compliance obligations while understanding the consequences of non-compliance and proposed legislative changes that could significantly impact audit procedures.

Découvrez les stratégies juridiques pour contester une nouvelle cotisation relative aux prix de transfert au Canada, incluant les recours devant l'ARC, la Cour canadienne de l'impôt et les procédures amiables internationales. Ce guide examine les facteurs décisionnels critiques, les considérations liées aux litiges fiscaux et le rôle des témoins experts dans la résolution de différends complexes en matière de prix de transfert.