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Canada’s 2025 Federal Budget: What it Means for Businesses, Investors, and Canadian Taxpayers
Confidence Level: High (95%) As an expert and consultant, the following analysis examines key measures from Canada’s 2025 Federal Budget tabled on November 4, 2025, highlighting the fiscal, corporate, real-estate,…
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What Landmark Israeli Transfer Pricing Case, Hexadite Ltd. V. Israel Tax Authority, Means for U.S. Multinationals
The Israeli District Court decision in Hexadite Ltd. v. Israel Tax Authority provides important lessons on transfer pricing, valuation of intangibles, and post-acquisition business-model changes. The ruling clarifies how contingent…
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Case Commentary: Rotfleisch v. Attorney General of Canada – Filing an Objection Does Not Stop the Alleged Tax Owing from Accumulating Interest
A recent Federal Court decision, David Jacob Rotfleisch v. Attorney General of Canada, 2025 FC 1529, reminds taxpayers that a lengthy delay by the Canada Revenue Agency (CRA) in resolving…
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A Tax Payment 2,700 Years Late Echoes CRA Backlog: Same Tax Problems Plague Assyrian Tribute and Modern Bureaucracy
A Clay Tablet 2,700 Years Old and CRA Delays A recent archaeological discovery near Jerusalem’s Temple Mount—reported by Haaretz on October 22, 2025—revealed an Assyrian cuneiform inscription hinting at possible…
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Israel’s 2025 Voluntary Disclosure Procedure: Critical Updates and Clarifications for Canadian Taxpayers with Israeli Ties
August 2025 Changes: Launch of the Israeli Voluntary Disclosure Procedure (VDP) In August 2025, the Israel Tax Authority (ITA) launched a comprehensive Voluntary Disclosure Procedure (VDP), designed to encourage taxpayers…
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How Limited Partnerships Are Taxed in the U.S.: Insights, Advantages, and Drawbacks from a U.S. Tax Lawyer
An Overview of U.S. Limited Partnerships A Limited Partnership (LP) is a pass-through entity formed under state law that includes at least one general partner (GP) and one or more…
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IRS Reverses Course on DeFi Broker Rule: Impact on U.S. Crypto Investors and DeFi Platforms
Overview The U.S. cryptocurrency sector continues to evolve as regulators clarify crypto tax obligations. In April 2025, Congress overturned the IRS’s proposed expansion of the “broker” definition under the Infrastructure…
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![Economic Substance Doctrine [§7701(o)]: Critical Developments and Policy Implications to Prevent Abuse in U.S. Tax Law](data:image/svg+xml,%3Csvg%20xmlns='http://www.w3.org/2000/svg'%20viewBox='0%200%20768%20512'%3E%3C/svg%3E)
Economic Substance Doctrine [§7701(o)]: Critical Developments and Policy Implications to Prevent Abuse in U.S. Tax Law
The Economic Substance Doctrine, codified under IRC §7701(o), is a critical anti-abuse rule in U.S. tax law. It ensures transactions have both a meaningful economic effect and a legitimate non-tax…
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U.S. Life Insurance Withdrawals: Tax Implications and Strategies
Permanent life insurance policies—such as whole life, universal life, and variable life—are valuable financial tools that provide both protection and cash value accumulation. Understanding how withdrawals are taxed helps policyholders…
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Israel’s 2025 Voluntary Disclosure Procedure: Updates and Clarifications for U.S. Taxpayers with Israeli Ties
August 2025 Changes: Launch of the New Israeli Voluntary Disclosure Procedure (VDP) In August 2025, the Israeli Tax Authority (ITA) introduced a new Voluntary Disclosure Procedure (VDP), designed to allow…
![Economic Substance Doctrine [§7701(o)]: Critical Developments and Policy Implications to Prevent Abuse in U.S. Tax Law](https://taxlawyer.com/wp-content/uploads/2025/10/Handcuffs-on-top-of-a-stack-of-American-currency-with-tax-forms-beneath-it-on-a-desk-768x512.jpeg.webp)
