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1
The Second Anniversary Of The Disastrous Canadian Private Corporation Tax Proposals
Today is the second anniversary of the disastrous rollout of the July 18, 2017, Canadian private corporation tax proposals.
Canada
23 Jul 2019
2
Case Notes For July, 2019
Section 116 of the Act provides rules that protect the Canadian government's ability to collect tax on capital gains on a disposition of "taxable Canadian property".
Canada
11 Jul 2019
3
Proposed Changes To The Canadian Taxation Of Employee Stock Options
As most readers know, in a bit of a surprise announcement the 2019 Federal Budget announced changes to the existing taxation treatment of employee stock option benefits to fully tax certain benefits.
Canada
11 Jul 2019
4
2019 STEP Canada CRA Roundtable
On Friday June 7, 2019, the Canada Revenue Agency ("CRA") Roundtable of the annual STEP Canada National Conference was held.
Canada
11 Jul 2019
5
Advice For Cross Border Travelers – Tips For Snowbirds
"Snowbirds" are Canadian citizens / residents who flock annually to warmer US climates to avoid Canadian winter weather.
Canada
11 Jul 2019
6
Introducing CaseNotes
As tax practitioners, a good chunk of our careers are spent keeping up-to-date on changes in tax law. Changes can arise from legislative amendments, case law that helps to interpret complex
Canada
7 Jun 2019
7
"Mummy, Am I An American?" A Tax Nightmare, In One Act
Figuring out whether you are an American citizen can bring with it some incredibly complex and onerous tax surprises.
United States
28 May 2019
8
US Customs & Border Protection Rejecting L-1 Renewals
Until quite recently, Canadian citizens were able to submit renewal L-1 nonimmigrant visa petitions at US ports-of-entry.
Canada
15 Apr 2019
9
Surprise! Foreign Affiliate Dumping Rules Coming To A Private Business Near You
The Foreign Affiliate Dumping ("FAD") rules, contained in section 212.3 of the Income Tax Act (the "Act"), are 10 pages of the Act that many Canadian advisors ...
Canada
1 Apr 2019
10
2019 Federal Budget – Spend, Spend, Spend, With No Real Competitiveness Measures
Well, the 2019 Federal Budget was released today. Overall, outside of a couple of surprises, the tax content was almost not newsworthy.
Canada
29 Mar 2019
11
IRS Regulations Clarify GILTI Tax Relief To US Individual Shareholders With The Sec. 962 Election
One of the many goals of US tax reform implemented by the Tax Cuts and Jobs Act of 2017 ("The Act") was to incentivize large multi-national enterprises that were perceived to be storing profits
United States
21 Mar 2019
12
50 Ways to Leave – Tax Considerations For Departing Canadian Individuals
Residency is central to the taxation of Canadians.
Canada
5 Mar 2019
13
USCIS Releases Final H-1B Pre-Registration Rule – Impact For FY2020 H-1B Cap Filings
On January 31, 2019, the US Department of Homeland Security (DHS) published the final H-1B cap registration rule requiring pre-registration by employers seeking to file H-1B petitions.
Canada
8 Feb 2019
14
A Critical Review Of Recent Canada Revenue Agency Views On TOSI And How To Use Them To Your Advantage
Since coming into effect at the start of 2018, the new "tax on split income" or "TOSI" rules have been a source of anxiety for financial professionals advising private business owners due to its broad scope and complexity.
Canada
4 Feb 2019
15
It's Time For An Update In The Accounting World
It's time for an update in the accounting profession. Firstly, the use of the title "accountant" should be regulated; and secondly, while we're at it, it's also time for a tax specialization designation.
Canada
16 Jan 2019
16
Relief Coming For US Citizens Living Abroad? Unfortunately, We Don't Think So
Providing such people with false hope is disappointing.
Canada
7 Jan 2019
17
Baby, There's High Tax Rates Outside
I really can't stay (but baby there's high tax rates outside).
Canada
27 Dec 2018
18
Morneau's Fall Fiscal Update Disappoints On Tax Competitiveness
Finance Canada's economic update provided a weak response to competitiveness concerns.
Canada
7 Dec 2018
19
New Canadian Beneficial Ownership Reporting Requirements Affecting Certain Corporations May Soon Become Law
The Canadian federal government recently introduced Bill C-86, Budget Implementation Act, 2018, No. 2 (Bill C-86) (the "Bill").
Canada
5 Dec 2018
20
How To Not Respond In A Non-Knee-Jerk Fashion To US Tax Reform
Eleven months since the US released and effectuated historical tax reform (and eleven months of listening to the Canadian Department of Finance's standard speaking point stating that they will not respond to US tax reform in a knee-jerk fashion), ...
Canada
23 Nov 2018
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