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Living Abroad? A Tax Lawyer Explains What the Shakira Tax Case Teaches Americans About Moving Wealth
Shakira Tax Case Overview: Essential Insights on Tax Residence for High-Net-Worth Americans Colombian superstar Shakira has secured an important win against Spanish tax authorities. Spain’s High Court cleared her of…
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How to Beat CRA Alternative Tax Assessments: Insights from a Canadian Tax Lawyer
Overview: The Canada Revenue Agency’s Alternative Tax-Assessment Techniques & How to Beat Them When the Canada Revenue Agency’s tax auditors can’t rely on your official books and records—whether it’s because…
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Panama Papers 10th Anniversary: U.S. Tax Implications, IRS Results & Compliance Lessons for American Taxpayers
10 Years Later: What the Panama Papers Mean for U.S. Taxpayers and Offshore Compliance April 2026 marks the 10th anniversary of the Panama Papers, one of the largest data leaks…
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Is the CRA Easier on You Than the IRS? A Canadian Tax Lawyer Explains Their Different Tactics, Processes
Overview: Understanding CRA vs IRS Enforcement The perception that Internal Revenue Service enforcement is stronger than Canada Revenue Agency enforcement is common among taxpayers and advisors, particularly in cross-border contexts. …
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CRA vs. IRS Audits: What Every Canadian Tax Lawyer Wants You to Know
Overview of CRA Tax Audits and IRS Audit Processes for Cross-Border Taxpayers Cross-border taxpayers, corporations, investors, and high-net-worth individuals increasingly face scrutiny from both the Canada Revenue Agency (CRA) and…
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IRS Reporting Requirements for Foreign Exchange Bureaus: Your Complete BSA Compliance Guide for Currency Exchange Businesses
Overview of IRS and FinCEN Rules for Foreign Exchange Bureaus in the US Foreign exchange bureaus operating in the United States face rigorous IRS and FinCEN oversight due to their…
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What are the IRS Digital Asset Reporting Rules (2026)? Form 1099-DA, Crypto Tax Compliance, & IRS Enforcement Risks on Crypto Currencies
Overview: IRS Digital Asset Reporting Framework and Form 1099-DA Compliance The Internal Revenue Service (IRS) has implemented a comprehensive digital asset reporting framework centered on Form 1099-DA, fundamentally transforming how…
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How to Meet the Very High Bar for Establishing and Maintaining Canadian-Controlled Private Corporation (CCPC) Status, plus Corporate and Tax Implications of Share Transfer
The classification of a corporation as a Canadian-controlled private corporation (CCPC) is one of the most significant tax designations a private enterprise can achieve. This status unlocks a suite of…
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Smith v. The King – Missed the Deadline to Object to a CRA Tax Reassessment? What the Tax Court Requires to Grant an Extension of Time
Introduction – Why Missing a Deadline Is Not the End, But Procedure Is Everything When a taxpayer misses the deadline to file a notice of objection to a CRA tax…
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Gill v. The King -Transferring Property Among Family Members, when You’re in Debt to CRA? That Triggers Secondary Tax Liability (because it Appears to be a Tax Dodge)
Background: Section 160 and Derivative Tax Liability Section 160 of the Income Tax Act (ITA) is one of the most potent collection tools available to the Canada Revenue Agency (CRA).…
