Publications

Newsletters

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U.S. Tax Tips

Jan 17, 2019

2019 U.S. Tax Rates

On November 15, 2018 the IRS issued Revenue Procedure 2018-57. … Read more »

Jan 08, 2019

The Tax Fairness for Americans Abroad Act of 2018 [Proposed]

On December 20, 2018, just before the Congressional holiday recess,… Read more »

Dec 11, 2018

Interest Deductibility

The Tax Cuts and Jobs Act of 2017 (“TCJA” P.L…. 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 »