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Business and Capital Property Gifts in Canada: Taxable Benefits, Capital Gains Tax, and Using a ‘Deed of Gift’ to Protect Property Transfers
Gifting in Canada: Tax Implications and the Role of a Deed of Gift Canada does not have a gift tax, unlike other jurisdictions, notably the United States. However, there are…
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Italy’s Rising Tax Evasion vs the United States’ is Higher, even with the Voluntary Disclosure Program (VDP)
Tax compliance challenges vary significantly across jurisdictions, and the approaches taken to address tax evasion reflect differing policy philosophies. Italy has faced persistent issues with tax evasion, while the United…
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Canada’s 2025 Federal Budget: What it Means for Businesses, Investors, and Canadian Taxpayers
Confidence Level: High (95%) As an expert and consultant, the following analysis examines key measures from Canada’s 2025 Federal Budget tabled on November 4, 2025, highlighting the fiscal, corporate, real-estate,…
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What Landmark Israeli Transfer Pricing Case, Hexadite Ltd. V. Israel Tax Authority, Means for U.S. Multinationals
The Israeli District Court decision in Hexadite Ltd. v. Israel Tax Authority provides important lessons on transfer pricing, valuation of intangibles, and post-acquisition business-model changes. The ruling clarifies how contingent…
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Case Commentary: Rotfleisch v. Attorney General of Canada – Filing an Objection Does Not Stop the Alleged Tax Owing from Accumulating Interest
A recent Federal Court decision, David Jacob Rotfleisch v. Attorney General of Canada, 2025 FC 1529, reminds taxpayers that a lengthy delay by the Canada Revenue Agency (CRA) in resolving…
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A Tax Payment 2,700 Years Late Echoes CRA Backlog: Same Tax Problems Plague Assyrian Tribute and Modern Bureaucracy
A Clay Tablet 2,700 Years Old and CRA Delays A recent archaeological discovery near Jerusalem’s Temple Mount—reported by Haaretz on October 22, 2025—revealed an Assyrian cuneiform inscription hinting at possible…
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Israel’s 2025 Voluntary Disclosure Procedure: Critical Updates and Clarifications for Canadian Taxpayers with Israeli Ties
August 2025 Changes: Launch of the Israeli Voluntary Disclosure Procedure (VDP) In August 2025, the Israel Tax Authority (ITA) launched a comprehensive Voluntary Disclosure Procedure (VDP), designed to encourage taxpayers…
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How Limited Partnerships Are Taxed in the U.S.: Insights, Advantages, and Drawbacks from a U.S. Tax Lawyer
An Overview of U.S. Limited Partnerships A Limited Partnership (LP) is a pass-through entity formed under state law that includes at least one general partner (GP) and one or more…
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IRS Reverses Course on DeFi Broker Rule: Impact on U.S. Crypto Investors and DeFi Platforms
Overview The U.S. cryptocurrency sector continues to evolve as regulators clarify crypto tax obligations. In April 2025, Congress overturned the IRS’s proposed expansion of the “broker” definition under the Infrastructure…
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![Economic Substance Doctrine [§7701(o)]: Critical Developments and Policy Implications to Prevent Abuse in U.S. Tax Law](data:image/svg+xml,%3Csvg%20xmlns='http://www.w3.org/2000/svg'%20viewBox='0%200%20768%20512'%3E%3C/svg%3E)
Economic Substance Doctrine [§7701(o)]: Critical Developments and Policy Implications to Prevent Abuse in U.S. Tax Law
The Economic Substance Doctrine, codified under IRC §7701(o), is a critical anti-abuse rule in U.S. tax law. It ensures transactions have both a meaningful economic effect and a legitimate non-tax…
![Economic Substance Doctrine [§7701(o)]: Critical Developments and Policy Implications to Prevent Abuse in U.S. Tax Law](https://taxlawyer.com/wp-content/uploads/2025/10/Handcuffs-on-top-of-a-stack-of-American-currency-with-tax-forms-beneath-it-on-a-desk-768x512.jpeg.webp)