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  • Article

    Another Turn At Cheek: Willfulness And Non-US Residents

    Since 2012, US citizens living in Canada (and elsewhere outside the US) have had two options to address income tax non-compliance issues.
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    Do Not Get Out Of IRS’s Tax Amnesty Programs Without Knowing The Facts

    In light of the IRS’s new streamlined procedure for bringing the delinquent tax returns of US persons current, many taxpayers who are currently in the 2009 Offshore Voluntary Disclosure Program (OVDP) or 2011 Offshore Voluntary Disclosure Initiative (OVDI) are considering opting out of these amnesty programs in the hope of filing under the new procedure.
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
Article

Enhanced Tax Reporting For Trusts Starting 2022

On August 9, 2022, the Department of Finance released the latest draft legislation with respect to Enhanced Reporting Requirements for Trusts first introduced in the 2018 Federal Budget.
CanadaTax
Moodys Private Client Law
Moodys Private Client Law
  • Article

    Rethinking Your Firm's Cross-Border Tax Strategy: The Impact Of Donald Trump's Business Tax Reform On Canadian Entrepreneurs

    It is safe to say President-elect Trump ran a presidential campaign that was bold, filled with fiery rhetoric, and sometimes knew no bounds.
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    So You Want To Move To Canada?

    It seems like every time there is an American election, Google is inundated with search traffic from panicked Americans looking to move to Canada.
    CanadaImmigration
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    Would A Pickup Truck By Any Name Be As Depreciable?

    On January 31, 2013, the Tax Court of Canada released two decisions, which are of particular interest for business owners who use motor vehicles and for their tax advisors.
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    The Top 10 Most Frequently Asked Questions About Renouncing US Citizenship. Get The Truth!

    A massive shift is taking place among US citizens living abroad: nearly half are now considering renouncing their US citizenship.
    United StatesTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    Recently Released GILTI Regulations May Create Tax Nightmares For Many US Shareholders Residing In Canada

    While GILTI is a US tax, it can be a significant problem for US shareholders resident in Canada. As explained below, provisions which reduce Canadian taxes owing may ultimately result in...
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    Relevant Factors In Employee Or Independent Contractor Determination

    A determination of whether an employee or independent contractor relationship applies between parties will significantly impact tax obligation and liability.
    CanadaEmployment and HR
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    Treaty Shopping Explained – Velcro Canada Inc. v. The Queen

    The Canada Revenue Agency ("CRA") recently lost in Tax Court against a taxpayer that had structured their operations to minimize Canadian tax.
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    Private Corporation Tax Proposals Unquestionably Harm "Middle-Class" Business Owners

    On July 18, 2017, the Liberal Government announced a significant set of tax proposals purported to close "tax loopholes" and "strategies that can result in high-income individuals gaining tax advantages that are not available to most Canadians."
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    Tax In Canada And The US: The Differences That Really Matter

    Many people assume that the US and Canadian tax systems for individuals are similar.
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    PSB Hazards When Providing Services Through A Corporation

    An individual who provides services may choose to incorporate for commercial or tax advantages. Depending on the circumstances, significant tax efficiencies can be gained by incorporating.
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    Canada Passes COVID-19 Economic Response Plan Into Law – Our Tax Take

    Today, on March 25, 2020, Canada enacted Bill C-13 An Act respecting certain measures in response to COVID-19 (the "Bill").
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    The Impact Of High Personal And Corporate Tax Rates

    Recently, I had the honour and pleasure of speaking at one of Canada's premier tax and estate planning conferences.
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    The Loss Restriction Event Rules For Trusts Are Broader Than You Think

    Loss carryforwards and other tax attributes, such as scientific research and experimental development ("SR & ED") expenditures, investment tax credits ("ITCs"), resource pools, are valuable assets because they can shelter taxes.
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    Why Canadian Residents May Soon Owe Tax To The IRS

    US tax rates are scheduled to go up next year—to levels even higher than Canada's.
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    IRS Hates Quiet Disclosures And They Really Mean It

    The US Government Accountability Office recently released a report that encouraged the Internal Revenue Service to seek out off-shore filers who have circumvented the IRS’s recent Voluntary Disclosure programs in favor of "quiet disclosure."
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    Will Charities Suffer From The Proposed AMT Legislation?

    The alternative minimum tax ("AMT") was first introduced in 1986 to ensure that individuals and trusts pay some amount of minimum tax where they otherwise would not (or would pay what was perceived...
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    Australian Superannuation Reforms May Negatively Impact US Citizens

    Last May 4, President Trump and Prime Minister Turnbull celebrated the 75th anniversary of the Battle of the Coral Sea in New York aboard the USS Intrepid, a World War II aircraft carrier.
    United StatesTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Showing 341–360 of 441 results

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