Articles
U.S. Tax Law Articles
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GENIUS Act Crypto Tax Guide 2025-2026: What US Investors, Businesses, and Taxpayers Need to Know About the New Stablecoin Law, Form 1099-DA, and Digital Asset Regulation
Overview: The New US Cryptocurrency Legal Landscape — Enacted Laws, Pending Bills, and IRS Rules Americans Must Know The United States cryptocurrency regulatory landscape has undergone its most dramatic transformation…
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IRS to Cut Penalties in Overhauled Criminal Voluntary Disclosure Program
Overview: IRS Preparing Lower Penalties for the Criminal Voluntary Disclosure Program The Internal Revenue Service is preparing to roll out a substantially revised Criminal Voluntary Disclosure Program (VDP), and the…
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IRS Quietly Ends the Delinquent FBAR Submission Procedures: What American Taxpayers with Unreported Foreign Accounts Should Do Now
No IRS relief program is permanent, and the agency rarely gives taxpayers advance warning before one disappears. On July 1, 2026, that lesson repeated itself: the IRS quietly eliminated the…
Canadian Tax Law Articles
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When Relying on a Tax Preparer and Ignoring Tax-Return Red Flags Becomes Wilful Blindness: A Canadian Tax Lawyer’s Analysis of Kane v. The King
Contents Overview: When Tax-Return Red Flags Can Lead to a CRA Gross Negligence Penalty Background: How a Fictitious Business Loss Led to a CRA Tax Penalty in Kane When Does…
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Bare Trust Tax in Canada: Beneficiary Changes, Trustee Changes and Death Dispositions
What are the Tax Rules for Bare Trusts in Canada? Plus, Trustee Changes, Beneficiary Additions & ‘Deemed Disposition’ at Fair Market Value at Death Overview A bare trust is generally…
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Tax Court Shuts Down Foreign Continuance Loophole: CRA can Tax a Canadian-Controlled Private Corporation (CCPC): Lessons from Somerset Limited v The King, 2026 TCC 123
Contents Overview – Why the Offshore Continuance Failed In Somerset Limited v The King, 2026 TCC 123, the Tax Court of Canada considered whether a Canadian private corporation could reduce…
