Searching Content indexed under Tax Treaties by Moodys Gartner Tax Law LLP ordered by Published Date Descending.
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New IRS Campaigns On Withholding And International Individual Tax Compliance
The IRS announced on May 21, 2018, the rollout of six additional compliance campaigns to be undertaken by the Large Business and International Division (LB&I).
25 May 2018
The Impact Of Select US Tax Reform Provisions On Australian Superannuation Funds And Its Beneficiaries
Last week, Australian Prime Minister Malcolm Turnbull and President Trump commemorated the first 100 years of mateship between Australia and the United States.
United States
27 Feb 2018
The Liberals Came Up With A Solution. Now They Are Desperate To Find A Problem For It:
The latest chapter in the ongoing battle against Ottawa's proposed changes to private company taxation unfolded this week.
28 Sep 2017
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 States
15 May 2017
Canada Revenue Agency Expands Relief For Canadian Taxpayers With US LLLPs And LLPs
During the Canada Revenue Agency (CRA) roundtable at the International Fiscal Association (IFA) conference in Toronto earlier this week, the CRA announced "administrative grandfathering" for...
3 May 2017
Renouncing Your US Citizenship: Is Divorcing Uncle Sam Right For You?
The billionaire co-founder of Facebook, the only American member of Monty Python, a Civil Rights Leader with a Ph.D. from Harvard, the founder of Carnival Cruise Lines and owner of the Miami Heat NBA franchise, . . .
14 Mar 2017
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.
2 Feb 2016
2016 Canadian Federal Budget Predictions
In what's becoming our firm's annual tradition, the purpose of this blog is to gaze into the crystal ball to predict what the tax goodies might look like when the 2016 federal budget is released.
25 Jan 2016
Canadian Challenge To FATCA
In its 2015 budget, the federal government announced a commitment to implement the OECD's common reporting standards starting in July 2017 and reaffirmed Canada's commitment to introduce draft legislation in 2015.
4 Nov 2015
Decision In Canadian Challenge To FATCA Expected Soon
The Canadian Federal Court heard oral arguments on August 4 and 5 in a lawsuit that challenges the law that implements the intergovernmental agreement between Canada and the U.S. relating to the Foreign Account Tax Compliance Act.
1 Sep 2015
Planning Using Principal Residence Trusts For Immigrants To Canada
As many of our readers know, the Canadian Income Tax Act (the "Act") provides for an unlimited exemption from the imposition of Canadian income tax on the gains resulting from a disposition of a "principal residence".
10 Jul 2015
Recent Court Decisions - May 2014
The last year has provided no shortage of exciting and interesting tax cases that tax practitioners can learn from.
28 May 2014
Report On Legislative Proposals Relating To Canada – United States Enhanced Tax Information Exchange Agreement
Moodys Gartner is pleased to provide you with this written submission on the draft legislative proposal relating to the Canada – US Tax Information Exchange Agreement.
12 Mar 2014
Summary Of Comments On Canadian FATCA legislation
Canada and the U.S. executed a model 1 intergovernmental agreement which relieved Canadian financial institutions from many onerous obligations under FATCA.
11 Mar 2014
"Black Is The New Grey" – Treaty Interpretation In The Conrad Black Appeal
Winston Churchill said there is "no such thing as a good tax" and thus it surely follows that no good can come from double taxation.
19 Feb 2014
In FATCA-Land, A Canadian Trust Is A Bank
When Alice found herself in Wonderland, she observed a recognizable world that had been turned on its side.
11 Feb 2014
Canadian SnowBirds Beware! 2014 Border Crossing Rules Increase Stakes For "Day Count"
Virtually all Canadian snowbirds know they must keep track of how many days they are in the US and outside of Canada because "bad" tax and non-tax surprises await those who are in or out of either country too long.
26 Nov 2013
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.
4 Mar 2013
Moodys Tax Advisors Proposes Legislation To Allow Canadians To Deduct Professional Fees Paid In IRS’s Voluntary Disclosure Programs
Our 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.
18 Oct 2012
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