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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…
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Everything Canadian Families Need to Know about the Two Types of RESP Withdrawals: Tax-Free vs. Taxable Payments
Understanding the Taxation of RESP Withdrawals A Registered Education Savings Plan (RESP) is a cornerstone of educational financial planning in Canada. It allows families to save for post-secondary education through…
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How Americans Must Report ‘Spin-Off’ Shares under Section 355 of the Internal Revenue Code (IRC) in the U.S.
U.S. corporations occasionally restructure by separating one part of their business into a new corporation and distributing shares of the new company to existing shareholders. For U.S. residents, these shares…
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How Canadian Residents Must Report Foreign ‘Spin-Off’ Shares under Section 86.1 of the Income Tax Act
Foreign corporations sometimes restructure their business and distribute shares of a new or separate company to their existing shareholders. For Canadian residents, these shares are known as foreign spin-off shares,…
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When CRA is Allowed to Miss Deadlines, or Why You Need an Experienced Tax Litigation Lawyer in Tax Court: Golden Mind Investment Ltd. v. The King, 2025 TCC 77
Introduction: Tax Litigation & Examination for Discovery The Tax Court of Canada serves as a federal court that adjudicates disputes arising from tax matters between individuals or companies and the…
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