Top Gun: Maverick - Core Estate Plan and Gifting Basics
US Expatriate Tax Planning - Part 2 - A Podcast with Janathan Allen
How Tax Works - Entity Selection
TRAs: Benefits, Complexities (and Private Jets) Explained with Tax Attorney David Peck
REFRESH: Loot and Private Foundation Rules – Part 2
IRS Dirty Dozen Warnings on Charitable Scams
US Expatriate Tax Planning - Part 1 - A Podcast with Janathan Allen
GILTI Conscience Podcast | Spotlight Series: A Conversation With Women Trailblazers in Tax
Nonprofit Quick Tip: State Filings in North Carolina and South Carolina
Once Removed Episode 19: The Step-Transaction Doctrine and the Case of Smaldino
Digital Planning Podcast Episode: Planning for Influencers
Once Removed Episode 18: The Reciprocal Trust Doctrine
Business Better Podcast Episode: Tax Audits, Investigations, and Global Enforcement - A Conversation with IRS Special Agent Jonathan Schnatz
Charitable Planning With Guest Stephanie Hood: Navigating Complex Rules and Traps for the Unwary
The Presumption of Innocence Podcast: Episode 28 - Under the Microscope: Examining the Future of the ERC
Once Removed Episode 16: Gift and Estate Tax, Inflation Adjustments for 2024
Once Removed Episode 17: Annual Gifting to Individuals: Options, Opportunities and Pitfalls
GILTI Conscience Podcast | Inside the IRS: A Conversation With Former Agency Officials
The New Proposed Regulations on DAFs: Taxable Distributions and the Penalty Tax
GILTI Conscience Podcast | Pillar Two Analysis: An Asia Pacific Viewpoint
Canada’s Digital Services Tax Act was enacted on June 20, 2024 and came into effect by Order in Council on June 28, 2024. The new legislation imposes a digital services tax of 3% on digital services revenue exceeding...more
Le marché fragmenté de la distribution d’assurances au Canada continue de faire l’objet d’un grand volume d’activités de fusion et acquisition (« F&A ») alors que les consolidateurs établis regroupent de petits courtiers...more
The fragmented insurance distribution market in Canada continues to see significant levels of mergers and acquisitions (M&A) activity as established consolidators roll up smaller brokerages and managing general agents (MGAs),...more
A recent ruling from the Tax Court of Canada underscores the significance of tenants verifying their landlords' residency status in adhering to any obligations to withhold taxes in accordance with Part XIII of the Income Tax...more
Incentivizing employees is a critical component of most business strategies. Employers may implement arrangements for deferred cash bonuses, often subject to the satisfaction of certain criteria. From a tax perspective, the...more
Le 17 avril 2023, le ministère des Finances du Canada (le « Ministère ») a publié un avis de motion de voies et moyens (l’« Avis ») relatif à la mise en œuvre de certaines propositions prévues au budget fédéral de 2023....more
On April 17, 2023, the Department of Finance (Finance) released a Notice of Ways and Means Motion (NWMM) to implement certain proposals announced in the 2023 Federal Budget. The NWMM also includes much-awaited updated...more
Key Highlights - - Proposed 30 percent refundable Clean Technology Investment Tax Credit. - Proposed refundable Clean Hydrogen Investment Tax Credit. - Further details and consultations are forthcoming. -...more
The federal government's 2022 Fall Economic Statement (Economic Statement), released on November 3, 2022, introduced a new tax on share buybacks by public corporations in Canada. Under the proposal, which would come into...more
On June 9, 2022, the Tax Court of Canada (“TCC”) allowed CFI Funding Trust’s (“CFI”) appeal in relation with the input tax credits (“ITC”) it claimed for prepaid rent paid in connection with the securitization of automobile...more
On December 8, 2021, Alberta proclaimed in force Bill 77, the Municipal Government (Restoring Tax Accountability) Amendment Act, 2021 (the Amending Act), which is intended to strengthen municipal budgets following reports by...more
La Cour suprême du Canada (la « CSC ») a récemment rendu d’importantes décisions dans deux différends qui portaient sur des questions de fiscalité internationale. Dans l’affaire Canada c. Alta Energy Luxembourg S.A.R.L., 2021...more
The Supreme Court of Canada (SCC) recently released two important decisions relating to international tax issues. The SCC provided meaningful guidance on the interpretation of one of Canada’s bilateral tax treaties and the...more
The Duke of Westminster Principle Still Lives On for Tax Planning - On November 26, 2021, the Supreme Court of Canada released its decision and reasons in Her Majesty the Queen and Alta Energy Luxembourg S.A.R.L., 2021 SCC...more
In The Bank of Nova Scotia v The Queen, the Tax Court of Canada (TCC) considered how to calculate arrears interest on an audit adjustment that is offset by a loss carryback. ...more
On June 29, 2021, Bill C-208 was granted Royal Assent and became law in Canada. Bill C-208 amended the Income Tax Act (Canada) (the “Act”) to provide tax relief to families wishing to transfer shares of small business...more
In April 2021, the Canadian government released the 2021 federal budget, including a number of proposed tax changes. Many of these changes impact businesses in the U.S. that have operations in Canada, including with respect...more
The Spanish Supreme Court has recently issued a judgment concluding that a Canadian pension qualifies for the same tax treatment as Spanish pension funds and is therefore entitled to obtain the refund of the withholding tax...more
En raison de la situation sans précédent causée par la pandémie mondiale cette année, le gouvernement fédéral a reporté la présentation du budget qui devait avoir lieu en mars 2020. Le gouvernement a plutôt consacré, à juste...more
With the onset of this year’s unprecedented global pandemic, the federal government postponed the budget previously scheduled for March 2020. The government’s attention understandably shifted to the enactment of emergency...more
The clock is ticking for multinational enterprises and private equity firms with investments in the Canadian resource sector as anti-treaty shopping measures in the OECD's Multilateral Convention to Implement Tax Treaty...more
With the start of a new year, in-house counsel and human resources professionals will want to be aware of what’s on the horizon for 2020 and beyond. It’s a good time for employers to take a breath and consider what issues...more
Canadian companies and their outside counsel occasionally ask about the ability to grant early exercise incentive stock options (“ISOs”) to limit the impact of the U.S. alternative minimum tax (“AMT”) to their U.S. employees....more
According to the most recent estimates, the quantity of goods carried by containers has risen from around 100 million metric tons in 1980 to about 1.5 billion metric tons in 2012. Out of these numbers, one container in every...more
I spoke recently on a panel in Tokyo on the future of international tax planning after BEPS (the OECD’s & G20’s Action Plan to counter Base Erosion & Profit Shifting). The panel also featured a senior official at the OECD and...more