Publications

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Tax Tips

Oct 03, 2016

Canadian Tax Treatment of Certain Florida and Delaware Partnerships

the CRA views these entities to be corporations for Canadian… Read more »

Jul 20, 2016

Upstream Loans

taxpayers may need to act now  Prior to 2011, upstream… Read more »

Jan 11, 2016

Voluntary Disclosures – Time is of the Essence

“the initial submission can be made quickly, on a no-names… Read more »

U.S. Tax Tips

May 25, 2017

FATCA and Catch up Filing – Is the end in sight?

Since 2009, the U.S. Internal Revenue Service (“IRS”) has had… Read more »

Mar 27, 2017

Foreign Bank Account Reports – Make Sure to File Them

A United States person is required to file FinCEN Form… Read more »

Mar 17, 2016

Canadian Mutual Funds

Although this topic has been extensively covered in the Canadian… Read more »

Transfer Pricing Newsletter

May 29, 2017

Amazon makes the CUT – an important taxpayer win, a reminder to consider transactional evidence

This article also appears in the May issue of Insights,… Read more »

Dec 15, 2016

Is the CRA skipping dinner in the hope of getting its deserts? Digesting the “new” Canadian transfer pricing documentation standard

The CRA was recently asked “Will the CRA’s expectations of… Read more »

Sep 20, 2016

A new way to do the splits: BEPS draft guidance falls short of enabling global formulary apportionment

This article also appears in INSIGHTS vol 3 no 7… Read more »