North America: Tax

HMRC has extended its Structured Risk Review process to charities, introducing comprehensive scrutiny across all operational aspects including governance, fundraising, and subsidiary relationships. The review process involves extensive documentation requests and can result in penalties up to 100% of tax liability for identified errors. Charities must maintain robust tax compliance and governance practices as the SRR cannot be adequately prepared for at short notice.

Canada's Department of Finance has released draft regulations for a new simplified transfer pricing documentation regime under subsection 247(4.1), designed to reduce compliance burdens for eligible taxpayers and partnerships. The regime introduces streamlined requirements for small taxpayers with gross revenue up to C$25-million and certain small transactions, though questions remain about how the simplified analysis differs from existing documentation standards. An anti-avoidance rule ensures the regime c

No IRS relief program is permanent, and the agency rarely gives taxpayers advance warning before one disappears. On July 1, 2026, that lesson repeated itself: the IRS quietly eliminated the Delinquent FBAR Submission Procedures, a program that for over a decade had let taxpayers who missed a Foreign Bank Account Report, but had otherwise paid every dollar of tax they owed, catch up without penalty.