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New Canadian beneficial ownership reporting requirements affecting certain corporations may soon become law

The Canadian federal government recently introduced Bill C-86, Budget Implementation Act, 2018, No. 2 (Bill C-86) (the “Bill”). This Bill includes significant proposed changes to the Canada Business Corporations Act (“CBCA”) concerning the disclosure of beneficial ownership of shareholders of federal private corporations. If passed, the amendments to the CBCA will become legally effective six months after receiving

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How to not respond in a non-knee-jerk fashion to US tax reform

Eleven months since the US released and effectuated historical tax reform (and eleven months of listening to the Canadian Department of Finance’s standard speaking point stating that they will not respond to US tax reform in a knee-jerk fashion), the government of Canada today provided a non-response. We believe it’s fair to say, mission accomplished;

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Proposed H-1B Pre-Registration Rule for FY2020

On October 17, 2018, as part of the US Department of Homeland Security’s (DHS) “Fall 2018 Unified Agenda of Regulatory and Deregulatory Actions and Regulatory Plan,” DHS has announced the upcoming publication of a proposed regulation requiring the pre-registration of employers seeking to file H-1B petitions on behalf of applications subject to the H-1B cap

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Is Income Splitting Dead?

With the new “income splitting” rules (known as the “tax on split income” or “TOSI”) now law, effective January 1, 2018, I am constantly asked if income splitting is dead for business owners and their families. Whenever I’m asked this question – especially recently given that we just celebrated Halloween – I think of many

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Lost in the Haze? – Updates on Cannabis and Travel to the US

In August, we published a blog regarding cannabis and travel to the US. Since that publication, adult use of cannabis became legal in Canada and US Customs and Border Protection (“CBP”) has released additional clarification for some travellers to the US. Although medicinal and/or adult use of cannabis has been legalized in many jurisdictions for

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Renouncing US citizenship or giving up a green card in the Gulf: why and how to consider it

US citizenship or permanent resident status allows access to the largest economy in the world. Why would an American citizen living in the United Arab Emirates, or a Saudi Arabian resident with a US “green card,” ever consider giving up US status? Increasingly, the answer is one word: tax.  Unique among global powers, the United States taxes

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Reporting Australian Superannuation Funds as Foreign Trusts for Tax Purposes

When You Don’t Have a Pair of Magical Ruby Slippers Like Dorothy[1] Current US tax laws do not provide any definitive guidance on the US tax classification and treatment of hybrid foreign retirement plans such as an Australian Superannuation Fund (“ASF”).[2] In June 2015, the IRS issued a series of Private Letter Rulings (“PLRs”)[3] to

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Five More Things You Should Know About Major Changes in US Immigration

For anyone paying even moderate attention to the news over the past few years, it will come as no surprise that the Trump administration’s views on immigration have had a significant impact on US immigration policy and procedure, including marked sweeping changes to policies previously supported by the Obama, Bush, and Clinton administrations.  While not

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The Trump Transition Tax’s Impact on Certain Canadians: A Practical Solution for Ottawa to Consider

Every day, it seems, Finance Minister Bill Morneau fields questions about Canada’s international competitiveness considering the recently enacted US tax reforms, which became effective January 1, 2018, by the Tax Cuts and Jobs Act (“TCJA”). Indeed, the TCJA lowered US tax rates and handed out tax breaks to all kinds of entrepreneurs, businesses, and individuals.

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Trust Reporting Rules – Draft Legislation Released

As part of draft legislation released on July 27, 2018, the Department of Finance moves forward with new trust reporting rules that were announced in the 2018 Federal budget. The draft legislation did not contain many surprises. Having said that, the new trust reporting rules will be a big change for many trustees, beneficiaries and protectors of trusts who will now be required to adhere to additional reporting requirements.

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Five Things You Should Know – Cannabis and Travel to the US

It’s no secret that perceptions and laws regarding cannabis have changed significantly in recent years, with medicinal and adult use becoming legal in some form or another in Canada and many states in the US.  While travel to the US a couple of decades ago was easily accomplished with a Canadian driver’s license, the level

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