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The Methanex Case: Implications of ‘Treaty Shopping’ and Consequences on U.S. Tax Planning for Americans
Introduction On April 22, 2025, the Judicial Committee of the U.K. Privy Council released a pivotal decision in Methanex Trinidad v. Board of Inland Revenue ([2025] UKPC 20). The ruling…
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When CRA Denies Penalty Relief in Major Non-Compliance Cases: Offshore Income and Aggressive Tax Shelters (2020–2025)
Introduction Between 2020 and 2025, the Canada Revenue Agency (CRA) has maintained a stringent approach towards taxpayers involved in significant non-compliance, particularly concerning offshore income and aggressive tax shelters. While…
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A Canadian Tax Lawyer’s Guide for Digital Nomads Moving to Canada: Understanding Tax Residence and the Sojourner Rule
Introduction: Digital Nomads and Canadian Tax Compliance Canada offers an attractive environment for digital nomads seeking flexibility and stability. However, moving to Canada triggers complex tax obligations that must be…
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Employment Expense Deductions Canada: Luxury Clothing & Home Office Costs
Introduction: Understanding Employment Expense Deductibility for Luxury Items In Samotus v. The King, 2025 TCC 104, the Tax Court of Canada examined whether employees can deduct luxury clothing and home office…
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Canada 2025 Draft Tax Changes: Key Updates for Individuals, Corporations, and Trusts
Introduction: Canada’s 2025 Draft Tax Legislation Overview On August 15, 2025, the Department of Finance released over 250 pages of draft legislation and explanatory notes, signalling significant changes to Canada’s…
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CRA’s Expanding Use of Administrative Tax Penalties (2020–2025): What Canadian Taxpayers Need to Know Now
Introduction: CRA Penalties and Modern Enforcement Trends From 2020 to 2025, the Canada Revenue Agency (CRA) has significantly increased the use of administrative penalties as a core enforcement tool. These…
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California State Income Tax Law Changes: What Taxpayers Need to Know for 2025
Introduction California remains one of the highest-tax jurisdictions in the United States, and recent changes to state income tax law—alongside federal adjustments—significantly impact individuals, families, and businesses. The state has…
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New York State Income Tax Law Updates: What Taxpayers Need to Know for 2025 and Beyond
Introduction New York State has enacted major income tax changes in the FY 2025–2026 budget. These updates affect both high-income taxpayers and middle-class households, with critical implications for residency planning,…
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Illinois Announces Fall 2025 Tax Amnesty Program: What Taxpayers Need to Know
Illinois has rolled out a major tax amnesty initiative aimed at recovering millions in delinquent state taxes. For individuals and businesses, this program offers a valuable opportunity to resolve outstanding…
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Now is the Best Time to Fix Past Tax Mistakes: CRA Modernizes the Voluntary Disclosures Program (VDP) – New Rules Effective October 1, 2025
Introduction: Understanding the Purpose of the VDP The Canada Revenue Agency’s Voluntary Disclosures Program (VDP) is a cornerstone of Canada’s tax compliance system. It provides a structured and legally recognized…
