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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…
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Seven Essential Steps for Estate Administration Across Canada – Guidance from an Experienced Canadian Tax Lawyer
When an individual dies, all property, assets, and interests left behind constitute the estate. Estates may include bank accounts, investments, real property, business shares, personal possessions, cryptocurrency or NFTs, and…
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Comparing the U.S. Voluntary Disclosure Program to Israel’s New Tax Disclosure Plan
Introduction: Different Approaches to Tax Compliance Tax authorities worldwide continue to refine their voluntary disclosure programs to encourage taxpayers with unreported income to come forward. Israel recently launched a new…
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Landmark July 2025 U.S. Tax Case: What Taxpayers Need to Know About JM Assets, LP v. Commissioner
Introduction: Why This Case Matters for Taxpayers In July 2025, the U.S. Tax Court issued an important ruling in JM Assets, LP v. Commissioner that affects how the Internal Revenue Service (IRS)…
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A Canadian Tax Lawyer Explains Self-Reporting & Penalty Risks of Canada’s Enhanced Mandatory Tax Disclosure Rules
Canada Strengthens Mandatory Disclosure Rules On June 22, 2023, Parliament amended the Income Tax Act to significantly expand Canada’s mandatory disclosure regime, now set out in Sections 237.3 to 237.5. These changes…
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401(k) Retirement Plans: Expert Strategies for U.S. Employees and Employers from a U.S. Tax Lawyer
Introduction to 401(k) Plans for U.S. Employees A 401(k) plan is the cornerstone of retirement savings for millions of Americans, offering tax-advantaged contributions, employer matching, and long-term investment growth, and…
