Articles
U.S. Tax Law Articles
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Indiana Expands Tax Amnesty Program: New Law Adds Additional Eligible Tax Periods for Resolving Back Taxes
Introduction – Indiana Tax Amnesty Program Creates Opportunity to Resolve Outstanding State Tax Liabilities State tax amnesty programs provide a limited opportunity for taxpayers with unpaid tax liabilities to come…
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Los Angeles Proposes Cannabis Tax Amnesty: What Marijuana Businesses Need to Know Now About IRS Tax Risks, Section 280E Compliance, and Cannabis Tax Planning
Overview: Los Angeles Cannabis Tax Amnesty Proposal Highlights Major Tax Compliance Risks Los Angeles officials are considering a cannabis tax amnesty program designed to help struggling marijuana businesses resolve unpaid…
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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…
Canadian Tax Law Articles
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International Crypto Fraud Crackdown: How CRA Treats Tax Losses from Crypto Scams in Canada
Overview: Global Crypto Fraud Enforcement and Canadian Tax Consequences for Victims A recent international law enforcement operation has highlighted the growing scale and sophistication of cryptocurrency fraud, while simultaneously raising…
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Federal Court of Appeal Strikes Down CCPC Continuance Planning Under GAAR in Canada v. DAC Investment Holdings Inc: Guidance from Canadian Tax Lawyer
On February 20, 2026, the Federal Court of Appeal (FCA) released its decision in Canada v. DAC Investment Holdings Inc. (DAC), 2026 FCA 35, overturning the Tax Court of Canada’s…
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Closing the Loophole on Indirect Trust Transfers and the 21-Year Deemed Disposition Rule: New Measure in Budget 2025
Overview—The 21-Year Deemed Disposition Rule For Canadian tax planners and trust beneficiaries, the “21-year rule” is a critical milestone. Under the Income Tax Act (ITA), most personal trusts, such as…
