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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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Understanding CRA Form T106 and How It Compares to U.S. Reporting Requirements
What Is CRA Form T106? Canadian taxpayers who engage in cross-border dealings with related non-residents face special reporting requirements. One of the most important filings in this area is CRA…
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U.S. Reporting Requirements for Cross-Border, Related-Party Transactions: What U.S. Taxpayers Must Know Now for Compliance
Understanding the U.S. Equivalent to Canada’s T106 In Canada, taxpayers must file CRA Form T106 to disclose certain non-arm’s length transactions with non-residents. The United States does not have a…
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CRA Finally Unveils 100-Day Service Improvement Plan for 2025: How Canadian Taxpayers Should Benefit
CRA Service Challenges and Ombudsperson Concerns In 2025, Canadians faced prolonged delays with the CRA, including call answer rates below 40%in July 2025 and lengthy processing backlogs for T1 tax…
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Why Passive Foreign Investment Companies (PFICs) Can Have Severe Tax Consequences: A Guide for U.S. Taxpayers
Overview: Why PFIC Rules Matter Many U.S. taxpayers with global investments are unaware of the harsh U.S. tax rules that apply to Passive Foreign Investment Companies, commonly known as PFICs.…
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Case Comment: CFM Insurance, Inc. v. Commissioner – What American Taxpayers Should Know About How the IRS Views Microcaptive Arrangements v Tax Avoidance Schemes
Court: U.S. Tax CourtDate: August 4, 2025Citation: T.C. Memo. 2025-83 Facts CFM Insurance, Inc., a microcaptive insurance company, was established to provide insurance coverage to its parent company, Caputo’s New…
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CRA Tax Treatment of Crypto Staking on CSA Platforms: Guidance from Canadian Crypto Tax Lawyers
Canadian Crypto Asset Regulation: Current Landscape for Investors Although Bitcoin, the first cryptocurrency, was created in 2008, Canada’s approach to regulating cryptocurrencies and trading platforms (also called crypto exchanges) remains…
