Publications

Newsletters

Sign-up for Tax Tips and/or the Non-Arm's Length News on the right side of the page.

U.S. Tax Tips

Aug 20, 2018

The U.S. Repatriation Tax – IRC §965: Proposed Regulations Issued

On August 3, 2018 the IRS issued “final” proposed regulations… Read more »

Jul 30, 2018

FBAR Penalties – the Court Speaks (for now)

The Internal Revenue Service was handed a defeat with respect… Read more »

Jul 23, 2018

IRS Service Offerings – Available to Some, Not All

U.S. citizens abroad are burdened with the same federal tax… Read more »

Tax Tips

Jul 19, 2017

Tax Planning Bomb Shell

“Changes to strategies that have been the basis for shareholder… Read more »

Jul 10, 2017

Major changes to the Voluntary Disclosures Program

“relief from penalties will be significantly curtailed” The Voluntary Disclosures… Read more »

Oct 03, 2016

Canadian Tax Treatment of Certain Florida and Delaware Partnerships

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

Transfer Pricing Newsletter

Sep 27, 2017

Eaton A.P.A. cancellations were an abuse of I.R.S. discretion

This article appears in Insights vol. 4, Issue 9.  Insights… Read more »

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 »