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441 results found

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  • Article

    Three Important Changes To IRS Streamlined Filing Procedures For US Taxpayers Resident In Canada

    The IRS recently released answers to frequently asked questions regarding its new Streamlined filing compliance procedures.
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    US Expats Face Another Tax Setback In The Courts: Is It Time To Finally Renounce US Citizenship?

    Recent US court rulings have confirmed that foreign tax credits cannot offset the Net Investment Income Tax for American citizens living abroad, creating an additional layer of taxation even when income is already taxed in their country of residence. These decisions raise critical questions about the long-term viability of maintaining US citizenship for entrepreneurs and business owners who have permanently established their lives outside the United States.
    United StatesTax
Moodys Private Client Law
Moodys Private Client Law
  • Article

    Am I Still A US Citizen? Confusion Regarding Loss Of US Citizenship For Tax Purposes

    Unlike virtually every other developed country, the United States bestows upon its citizens the unique pleasure of being taxed on their worldwide income, regardless of where that income is earned.
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    The Federal Court Of Appeal Decision In Macdonald - The Best Things In Life Are Worth Waiting For

    On April 26, 2012, our firm wrote about the Tax Court of Canada’s decision in MacDonald that dealt with pipeline transactions and the possible application of subsection 84(2) of the Income Tax Act (the "Act").
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    Renouncing US Citizenship Or Giving Up A Green Card: Why And How To Consider It

    Israel and the United States share a strong bond, and U.S. citizenship or permanent resident status allows access to the largest economy in the world.
    United StatesTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    Fair Market Value Transfers Of Property To Trusts - The Federal Court Of Appeal Decision Of Sommerer

    Canadian tax practitioners often recommend the use of "inter vivos" trusts in tax and estate planning for private clients.
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    IRS Says Hundreds Of Thousands Of US Citizens Are Not Reporting Canadian Trusts

    The IRS has recently released statistics on the number of returns it received in 2010 from US citizens with foreign trusts.
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    New Draft Legislation Will Have A Great Impact On Traditional Estate Planning For Canadians

    On August 29, 2014, the Department of Finance released 100+ pages of draft legislation. Much of the draft legislation was to enact the 2014 Federal Budget proposals.
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    Significant Changes To The Canadian Principal Residence Deduction

    The Department of Finance released a series of measures on October 3, 2016, aimed at "...protecting the financial security of Canadians, supporting the long-term stability of the housing market...
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    The Top 3 Tax Changes To Look For With The "New" Liberal Minority Government

    One of my favourite strategy/management authors was Peter Drucker. He was a quote machine, but one of my favourites was:
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    Twelve Canada-US Tax Tips For 2016

    By now the 2015 holiday season is a distant memory, as are most of those well-meaning 2016 resolutions. For those individuals with both Canada and US tax issues, tax filing season is a few months away.
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    The "Super" Reason Australians Are Renouncing Their US Citizenship

    Many US citizens living in Australia and elsewhere around the world have found themselves faced with the difficult decision of whether to keep or renounce their US citizenship.
    AustraliaImmigration
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    A Non-Retroactive Rectification Order? Anderson Rectifies Agreement But Not Agreed Transaction

    Taxpayers who erroneously record an agreement in a manner that (per the erroneous documentation) would cause unintended tax consequences to arise may find relief in the equitable remedy of rectification.
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    Americans Living Abroad Face Double Taxation In 2013

    The Patient Protection and Affordable Care Act of 2010 included new section 1411, which imposes a 3.8 percent tax on net investment income on U.S.
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    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.
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    The Tax Season That Never Ends (Version May 25, 2020)

    The Canadian personal tax season was nearly complete. Accountants all over Canada were working overtime to prepare 2019 T1...
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    The US "Transition Tax" For 2017: More Sad News For Many US Citizens Residing Abroad

    Transitions come in all different types, some good, some bad, and some just strange.
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    Whip That WIP: Canada's Proposed Tax Repeal Of A Professional's WIP Exclusion Election

    Earlier this week, we provided our summary of the 2017 federal budget released on March 22, 2017. The Budget contained a little-publicized but important tax change for how Canadian professionals...
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    Are United States Limited Liability Limited Partnerships The Holy Grail?

    One thing is for sure… Canadians continue to invest significant amounts of money in the US.
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    New Canadian Sales Tax Regime Cast On Digital Goods And Services Catches Non-resident Businesses, Both Big And Small

    The explosion of non-resident companies using the internet to sell their digital products and services without having the need for a permanent establishment in any country...
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Showing 301–320 of 441 results

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