Articles
U.S. Tax Law Articles
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CRA vs. IRS Service Levels: A Cross-Border Comparison of Tax Administration Risks for Canadian and U.S. Taxpayers
Overview: Why Administrative Performance Matters in Cross-Border Tax Planning For taxpayers operating in both Canada and the United States, the effectiveness of tax administration can materially influence compliance costs, dispute…
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IRS Service Levels for the 2026 Tax Filing Season: What Recent IRS Performance Means for U.S. Taxpayers
Overview: IRS Service Levels and Administrative Risk in U.S. Tax Compliance The Internal Revenue Service continues to publish performance indicators tied to call-centre access, processing timelines, and taxpayer assistance. These…
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How American ‘Jock Tax’ and State Income Tax Affect NFL Players, Other Professional Athletes: The Sam Darnold Super Bowl Example
The “jock tax” remains one of the most complex and strategically significant areas of U.S. state income taxation, particularly for NFL players, NBA players, MLB athletes, and other high-income professional…
Canadian Tax Law Articles
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CRA vs. IRS Service Levels: A Cross-Border Comparison of Tax Administration Risks for Canadian and U.S. Taxpayers
Overview: Why Administrative Performance Matters in Cross-Border Tax Planning For taxpayers operating in both Canada and the United States, the effectiveness of tax administration can materially influence compliance costs, dispute…
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Accepting Money from a Spouse with Tax Problems can Give you a Bigger Problem with CRA: Panneton v. The King (2024 TCC 24)
Introduction: When Your Spouse’s Tax Debt Becomes Your Debt The decision in Panneton v. The King is an important reminder of how strictly Canadian courts apply section 160 of the…
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When CRA Employees Misbehave and Make Mistakes Against Canadian Taxpayers
What the CRA’s 2024–2025 Report Reveals About Accountability, Privacy, and Public Trust The Canada Revenue Agency occupies a central role in administering Canada’s tax system, collecting public revenue, and safeguarding…
