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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…
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CRA May Apply 2025 Permanent Establishment OECD Rules to Canada: Remote Work, Authority to Bind, Treaty Interpretation & Interprovincial Tax Risk
Introduction: Permanent Establishment Canada, Remote Work, and OECD Influence on Courts Permanent establishment Canada analysis has become increasingly complex due to the OECD’s 2025 remote work guidance. Remote work permanent…
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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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Canada’s Anti-Deferral Regime and the FAPI Rules: When Offshore Trust Structures Trigger More Tax
Overview – Canada’s Approach to Offshore Income and Tax Deferral Canadian income tax law does not prohibit Canadian residents from using offshore entities or structures. What it does prohibit—explicitly and…
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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…
