On February 28, 2023, the U.S. Supreme Court released a 5-4 decision against the IRS’s position on the imposition of nonwillful violations of timely Foreign Bank Account Reporting (“FBAR”) reporting ...
TFSAs for U.S. citizens: might be worthwhile with some caveats
Since the Tax-Free Savings Account (TFSA) was introduced in 2009, it has been used by Canadians to earn investment income on a tax-free basis. Many U.S. citizens, however, have shied ...
Circuit court derails constitutional argument against the repatriation tax
In late 2017, the US Congress passed the Tax Cuts and Job Act (“TCJA”) which was signed into law by then President Trump on December 22, 2017. One of TCJA’s ...
Exploring Section 1031 Rollover in US Real Estate for Canadians
With current low capitalization rates in the Canadian real estate market, many Canadians are looking south of the border to the United States for higher returns on their real estate ...
Hello IRS, anybody home? The IRS continues to dig out from under reams of paper
If you feel like the IRS is not heeding your call, you are not alone. As the IRS continues to dig itself out of its pandemic-induced backlog, taxpayer service has ...
Preparing for the 2022 tax season
The Canadian government has moved quickly to offer economic relief and adjust tax regulations to benefit businesses and workers hit by economic challenges. To help you get up to speed, ...
Proposed legislation introduced to reform cannabis taxation in the US
On July 14, 2021, Senate Majority Leader Chuck Schumer released a discussion draft of a detailed cannabis reform bill which, if enacted, would restore the deductibility of all expenses related ...
The Biden Tax Plan: Where it stands
There has been a lot of talk in the recent news about the Biden tax plan moving forward in Congress. However, there is no need for panic (yet!), as the ...
US Court of Appeals Applies a Multi-Million Dollar Penalty on a Trust Distribution
In a recent case, the US Court of Appeals has upheld a significant penalty against the owner and beneficiary of a foreign trust distribution who did not file timely returns. ...