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U.S. Tax Tips

Mar 15, 2018

IRS Announces the end of the Offshore Voluntary Disclosure Program though Streamlined is still around – for now

On March 13, 2018 the Internal Revenue Service announced (IR-2018-52)… Read more »

Mar 13, 2018

The importance of E&P – Will you be paying the right amount of tax to the IRS?

An accurate determination of “earnings and profits” (E&P) of a… Read more »

Feb 27, 2018

IRS Form 5472 : An easy but expensive filing obligation to overlook?

Recent media coverage, as it relates to U.S. tax in… 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 »