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Panama Papers 10th Anniversary: U.S. Tax Implications, IRS Results & Compliance Lessons for American Taxpayers
10 Years Later: What the Panama Papers Mean for U.S. Taxpayers and Offshore Compliance April 2026 marks the 10th anniversary of the Panama Papers, one of the largest data leaks…
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Is the CRA Easier on You Than the IRS? A Canadian Tax Lawyer Explains Their Different Tactics, Processes
Overview: Understanding CRA vs IRS Enforcement The perception that Internal Revenue Service enforcement is stronger than Canada Revenue Agency enforcement is common among taxpayers and advisors, particularly in cross-border contexts. …
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CRA vs. IRS Audits: What Every Canadian Tax Lawyer Wants You to Know
Overview of CRA Tax Audits and IRS Audit Processes for Cross-Border Taxpayers Cross-border taxpayers, corporations, investors, and high-net-worth individuals increasingly face scrutiny from both the Canada Revenue Agency (CRA) and…
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IRS Reporting Requirements for Foreign Exchange Bureaus: Your Complete BSA Compliance Guide for Currency Exchange Businesses
Overview of IRS and FinCEN Rules for Foreign Exchange Bureaus in the US Foreign exchange bureaus operating in the United States face rigorous IRS and FinCEN oversight due to their…
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Indiana Expands Tax Amnesty Program: New Law Adds Additional Eligible Tax Periods for Resolving Back Taxes
Introduction – Indiana Tax Amnesty Program Creates Opportunity to Resolve Outstanding State Tax Liabilities State tax amnesty programs provide a limited opportunity for taxpayers with unpaid tax liabilities to come…
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Los Angeles Proposes Cannabis Tax Amnesty: What Marijuana Businesses Need to Know Now About IRS Tax Risks, Section 280E Compliance, and Cannabis Tax Planning
Overview: Los Angeles Cannabis Tax Amnesty Proposal Highlights Major Tax Compliance Risks Los Angeles officials are considering a cannabis tax amnesty program designed to help struggling marijuana businesses resolve unpaid…
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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…
