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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…
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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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How U.S. Businesses Can Deduct Outrageous Marketing “Loss Leaders” Expenses on Their Taxes: Lessons from a $3.2 Million Bluefin Tuna Purchase
Extraordinary promotional expenditures often attract scrutiny from the Internal Revenue Service (IRS), particularly when the amount paid for a single item appears disconnected from its intrinsic value. While U.S. tax…
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What American Taxpayers Need to Know About IRS Employee Misconduct, Confidentiality Breaches, and Governance Accountability
The Internal Revenue Service administers the United States federal tax system and is entrusted with extensive powers to collect revenue, conduct audits, issue tax assessments, and enforce compliance. Central to…
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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…
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CRA Introduces Software-Specific Controls for EFILE Accounts, a Safety Feature, Starting in 2026
Beginning in February 2026, the Canada Revenue Agency will introduce a new control mechanism within the EFILE and ReFILE systems that directly affects how electronic tax returns are transmitted. Under…
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Importing or Exporting More Than $10,000 in Cash? U.S. Reporting Laws, Federal Penalties, and Disclosure Considerations
U.S. Cross-Border Cash Reporting Rules: Key Compliance Issues for Individuals and Businesses Transporting cash into or out of the United States is legal, but it is subject to strict federal…
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How to Properly Claim Employment Insurance Repayments and Protect Your Tax Relief: Lessons from Dandees v. The King (2025 TCC 171)
Overview — EI Repayments, Tax Brackets, and the Limits of Timing Relief In Dandees v. The King, 2025 TCC 171, the Tax Court of Canada addressed a common but often…
