ArticleLooking To Make 2025 Your Last Year Of Filing US Taxes? Start Your Renunciation Journey Today.Every year, as June 15 rolls around, hundreds of thousands of Americans living abroad receive the same...CanadaTaxMoodys Private Client Law LLP
ArticleNew Individual Tax Identification Renewal RulesThe IRS started to accept 2016 individual tax returns on January 23, 2017. A nonresident alien individual must renew his or her Individual Taxpayer Identification Number (ITIN) in order to file...CanadaTaxMoodys Private Client Law LLP
ArticleThe Liberals Want To Wipe Out The Family Farm!?I don't write as many blogs as other members of my firm, however, today my concern rose enough to put fingers to keyboard.CanadaTaxMoodys Private Client Law LLP
ArticleAn Introduction To FATCA And Analysis Of Canada's LegislationThis article provides an introduction to the Foreign Account Tax Compliance Act (FATCA) for Canadians and analyzes Canada's implementing legislation regarding FATCA. CanadaTaxMoodys Private Client Law LLP
ArticleMessage To Canadian Owners Of US Rental Properties: The IRS Is Going To Be In Your NeighbourhoodIn a recent research study, the US Department of the Treasury identified a considerable number of non-resident aliens (NRAs) who were not reporting income from US rental propertiesCanadaTaxMoodys Private Client Law LLP
ArticleIs Income Splitting Dead?And somehow, the villain always seems to be resurrected magically. CanadaTaxMoodys Private Client Law LLP
ArticleIf You Have Foreign Entities, Get Ready For The New T1134 Forms For 2021The Canada Revenue Agency ("CRA") has released a preview of its new T1134 Summary and Supplement forms. CanadaTaxMoodys Private Client Law LLP
Article"Mummy, Am I An American?" A Tax Nightmare, In One ActFiguring out whether you are an American citizen can bring with it some incredibly complex and onerous tax surprises. United StatesTaxMoodys Private Client Law LLP
ArticleQuick Comments On The Office Of The Parliamentary Budget Officer Analysis Of Changes To The Taxation Of Corporate Passive Investment IncomeNot much has happened in the ongoing saga of the Canadian private corporation tax proposals since we last wrote about them. CanadaTaxMoodys Private Client Law LLP
ArticleSupreme Court Of Canada Upholds Rectification In Quebec Tax CasesThe Supreme Court of Canada recently released its decision in Quebec v. Services Environnementaux AES inc., 2013 SCC 65, which considered two cases where the Quebec Court of Appeal had allowed rectification as a remedy for taxpayers whose advisors had made an error in executing tax planning documentation. CanadaTaxMoodys Private Client Law LLP
ArticleThe US Pauses International Student Visa AppointmentsIn an unprecedented and disheartening move, the US has ordered the suspension of student and exchange visitor visa (including F, M, and J visas) processing as the administration ramps up its social media vetting process, according to a diplomatic cable, first reported by Politico, issued by US Secretary of State, Marco Rubio.CanadaImmigrationMoodys Private Client Law LLP
ArticleCanadian Decedents With US Real EstateOn July 31, 2015, the United States' Surface Transportation and Veterans Health Care Choice Improvement Act of 2015 added new Code sections 1014(f) and 6035. On March 2, 2016, the IRS released related regulations. CanadaTaxMoodys Private Client Law LLP
ArticleIRS May Require Snowbirds Stuck In The US To File Tax Returnswe discussed the immigration impacts of recent border closures and travel restrictions due to the COVID-19 pandemic for snowbirds and those on B-1 (business visitors) and B-2 (visitors for pleasure)CanadaTaxMoodys Private Client Law LLP
ArticleSupreme Court Of Canada Rules That FINTRAC Requirements Do Not Apply To Law Firms: Solicitor-Client Privilege Remains Strong In CanadaThe Financial Transactions and Reports Analysis Centre of Canada ("FINTRAC") is a government agency tasked with facilitating the detection, prevention, and deterrence of money laundering and the financing of terrorist activities.CanadaGovernment, Public SectorMoodys Private Client Law LLP
ArticleMoodys Tax Advisors Proposes Legislation To Allow Canadians To Deduct Professional Fees Paid In IRS’s Voluntary Disclosure ProgramsOur firm, Moodys Tax Advisors, has proactively proposed legislation in Canada that will, if accepted and passed, allow a deduction against Canadian tax for the vast amount of professional fees paid to participate in the Internal Revenue Service's ("IRS's") 2011 Offshore Voluntary Disclosure Initiative ("OVDI"), the 2012 Offshore Voluntary Disclosure Program ("OVDP"), or the (traditional) Voluntary Disclosure procedure. CanadaTaxMoodys Private Client Law LLP
ArticleCanada's Tech Talent Strategy: Creation Of Open Work Permit For U.S. H-1B Visa Holders‘Canada wants top talent from around the world.' That's the message that was delivered this week when Canada's Minister of Immigration, Refugees and Citizenship, Sean Fraser, launched the country's first-ever...CanadaImmigrationMoodys Private Client Law LLP
ArticleDai-Showa-Me-The-Money: (The Supreme Court Of Canada Decision In Daishowa-Marubeni V. R.)A discussion on the Supreme Court of Canada eagerly-anticipated decision in Daishowa-Marubeni v. R.CanadaTaxMoodys Private Client Law LLP
ArticleHot Times For Summer Tax Action - The Top FiveOur firm's tax groupies often ask us what is happening in the tax world. Given that we are in the heart of the summer, we thought it would be a good time to list the top five tax matters / issues that we are waiting for. CanadaTaxMoodys Private Client Law LLP
ArticleThe One Simple Question All Advisors Must Ask To Save Their Clients From An IRS Nightmare (And Save Them A Call To Their Malpractice Carrier).If you're a lawyer, accountant or financial advisor practicing outside the US, there is one simple question you must always address with every single one of your clients: are they an American citizen or Green Card holder?CanadaTaxMoodys Private Client Law LLP
ArticleUnwinding Non-CCPC StructuresA Canadian-controlled private corporation ("CCPC") that earns investment income is subject to a refundable tax regime. CanadaTaxMoodys Private Client Law LLP