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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…
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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…
