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2019 STEP Canada CRA Roundtable

On Friday June 7, 2019, the Canada Revenue Agency (“CRA”) Roundtable of the annual STEP Canada National Conference was held. I had the pleasure of once again being involved in the crafting / selection of the questions along with my good friend Michael Cadesky of Cadesky Tax. The Canada Revenue Agency was represented by Steve

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Introducing CaseNotes

As tax practitioners, a good chunk of our careers are spent keeping up-to-date on changes in tax law. Changes can arise from legislative amendments, case law that helps to interpret complex statutes or interpretations on legislation from the tax administrator—the Canada Revenue Agency (Canada) or the Internal Revenue Service (United States). In the midst of

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“Mummy, am I an American?” A Tax Nightmare, in One Act

Figuring out whether you are an American citizen can bring with it some incredibly complex and onerous tax surprises. You may be surprised to find out you are an American even if you have never set foot on US soil. And with that US citizenship comes tax on your worldwide income by Uncle Sam. In

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Client Alert – US Customs & Border Protection Rejecting L-1 Renewals

Until quite recently, Canadian citizens were able to submit renewal L-1 nonimmigrant visa petitions at US ports-of-entry. However, many Canadian citizens seeking renewals of their L-1 nonimmigrant visa petitions have recently been rejected by US Customs and Border Protection (CBP). Created in 1970 by the US Government to facilitate the movement of executives, managers, and

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Surprise! Foreign Affiliate Dumping Rules Coming to a Private Business Near You

The Foreign Affiliate Dumping (“FAD”) rules, contained in section 212.3 of the Income Tax Act (the “Act”), are 10 pages of the Act that many Canadian advisors of private enterprises could safely staple together and never open since its introduction in 2012. Well, as of March 19, 2019, these staples need to come off. Similar

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2019 Federal Budget – Spend, Spend, Spend, With No Real Competitiveness Measures

  Well, the 2019 Federal Budget was released today. Overall, outside of a couple of surprises, the tax content was almost not newsworthy. This summary discusses the tax content of the Budget that we believe is relevant to our clients and friends. For people that do not have the patience to wade through our entire

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IRS Regulations Clarify GILTI Tax Relief to US Individual Shareholders with the Sec. 962 Election

One of the many goals of US tax reform implemented by the Tax Cuts and Jobs Act of 2017 (“The Act”) was to incentivize large multi-national enterprises that were perceived to be storing profits offshore to bring those profits back to the United States to create jobs and growth. Accordingly, the Act introduced a carrot,

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A critical review of recent Canada Revenue Agency views on TOSI and how to use them to your advantage

Since coming into effect at the start of 2018, the new “tax on split income” or “TOSI” rules have been a source of anxiety for financial professionals advising private business owners due to its broad scope and complexity. The saga started on July 18, 2017 when the Department of Finance (“Finance”) introduced the first version

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Announcing our new co-leaders of our US Tax Practice Group, Directors Alexander Marino and Azam Rajan

Moodys Gartner Tax Law is proud to announce the co-leaders of our US Tax Practice Group, Directors of US Tax Law Alexander Marino and Azam Rajan. Together, they exemplify what we’re all about, bringing unique perspective, experience, and the forward-thinking required to turn complex tax issues into straightforward solutions. Join us in congratulating them as they lead

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