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CRA vs. IRS Service Levels: A Cross-Border Comparison of Tax Administration Risks for Canadian and U.S. Taxpayers
Overview: Why Administrative Performance Matters in Cross-Border Tax Planning For taxpayers operating in both Canada and the United States, the effectiveness of tax administration can materially influence compliance costs, dispute…
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IRS Service Levels for the 2026 Tax Filing Season: What Recent IRS Performance Means for U.S. Taxpayers
Overview: IRS Service Levels and Administrative Risk in U.S. Tax Compliance The Internal Revenue Service continues to publish performance indicators tied to call-centre access, processing timelines, and taxpayer assistance. These…
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How American ‘Jock Tax’ and State Income Tax Affect NFL Players, Other Professional Athletes: The Sam Darnold Super Bowl Example
The “jock tax” remains one of the most complex and strategically significant areas of U.S. state income taxation, particularly for NFL players, NBA players, MLB athletes, and other high-income professional…
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How U.S. Businesses Can Deduct Outrageous Marketing “Loss Leaders” Expenses on Their Taxes: Lessons from a $3.2 Million Bluefin Tuna Purchase
Extraordinary promotional expenditures often attract scrutiny from the Internal Revenue Service (IRS), particularly when the amount paid for a single item appears disconnected from its intrinsic value. While U.S. tax…
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What American Taxpayers Need to Know About IRS Employee Misconduct, Confidentiality Breaches, and Governance Accountability
The Internal Revenue Service administers the United States federal tax system and is entrusted with extensive powers to collect revenue, conduct audits, issue tax assessments, and enforce compliance. Central to…
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Importing or Exporting More Than $10,000 in Cash? U.S. Reporting Laws, Federal Penalties, and Disclosure Considerations
U.S. Cross-Border Cash Reporting Rules: Key Compliance Issues for Individuals and Businesses Transporting cash into or out of the United States is legal, but it is subject to strict federal…
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How to Ensure Compliance With Spot Exchange Rate Requirements Under U.S. Federal Tax Law
Foreign Currency Translation Rules, IRS Audit Risk, and Underreporting Prevention Foreign currency transactions are a routine and unavoidable feature of U.S. tax compliance for multinational corporations, cross-border businesses, investors, and…
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IRS Voluntary Disclosure Program 2026 Changes: Seeking Public Input on Tax Compliance for US Taxpayers and US Crypto Investors
Introduction to IRS Voluntary Disclosure Program Revamp and Public Comment Opportunities for Tax Compliance The Internal Revenue Service (IRS) is currently seeking public input on proposed enhancements to its Voluntary…
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U.S. Multinational Corporations Achieve Critical Exemption in OECD Global Minimum Tax
In the dynamic realm of international tax reform, U.S. multinational corporations have successfully negotiated a critical exemption within the OECD global minimum tax framework. This pivotal adjustment to the global…
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New Hampshire Tax Amnesty Program: A Limited-Time Opportunity to Resolve State Tax Debt
Introduction New Hampshire has introduced a temporary New Hampshire tax amnesty program designed to encourage taxpayers to voluntarily resolve outstanding state tax liabilities on favorable terms. Tax amnesty initiatives are…
