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Low Risk U.S. Tax Compliance

Andersen 01/01/1970
On June 26, 2012 the Internal Revenue Service (“IRS”) announced new streamlined filing procedures (“SFP”) for non-resident U.S. taxpayers to go into effect September 1, 2012. SFP is available to U.S. persons and dual citizens living outside the US who have failed to timely file ...
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Welcome to W.L. Dueck & Co. LLP – Providing Cross-border Tax Expertise Since 1998… and Commentary since 2012

Andersen 01/01/1970
Welcome to www.crossbordertaxblog.com, W.L. Dueck & Co. LLP’s U.S. and cross-border tax blog. We are a team of over 20 tax professionals that work exclusively on U.S. and cross-border tax issues. Our clients include Canadian businesses and individuals with investments in the U.S. and U.S. ...
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Going Toe to Toe with TOSI (Canada’s Tax on Split Income)

Andersen 01/01/1970
The federal government introduced the Tax on Split Income (“TOSI”) rules effective as of the start of 2018. The purpose of the rules was to prevent Canadian business owners from splitting their income in ways that were not available to salaried employees. For example, prior ...
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Canadian Covid-19 Small Business Tax Relief; Much Ado About Nothing

Andersen 01/01/1970
The Canadian federal government has announced its response to the Covid-19 Pandemic and is implementing a number of measures to help the economy.[1] In terms of cost, the largest of these measures are designed to increase liquidity and help Canadian firms maintain access to credit ...
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What is a business?

What is a Business? According to the Tax Court of Canada.

Andersen 01/01/1970
In two recent cases, the Tax Court of Canada dealt with the issue of “what is a business?” as opposed to a hobby, or something that is not quite yet a business. Callahan v. HMQ[1] and Hurwitz v. HMQ[2], were heard as informal procedure cases ...
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Harsh Result of s. 160(1) of the Canadian Income Tax Act.

Andersen 01/01/1970
Canadian Tax Cases – Mamdani Family Trust and Subsection 160(1). The recent case of Mamdani Family Trust v. HMQ[1] illustrates the absolute nature of subsection 160(1)of the Income Tax Act (the “Act”). The Mamdami Family Trust (the “Trust”) is an inter vivos trust resident in ...
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Top 5 Tax Issues: Canadians Doing Business in the U.S.

Andersen 01/01/1970
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Top 5 Tax Issues U.S. Estate and Gift Tax

Top 5 U.S. Estate and Gift Tax Issues for Canadians

Andersen 01/01/1970
The U.S. taxes transfers during an individual’s lifetime (gift tax) and at death (estate tax). These taxes apply to the net value of the asset transferred, not the net gain. Canada only taxes the net gain on assets transferred both before or after death. This article ...
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Importance of Governance Structures for Family Businesses

Andersen 01/01/1970
Governance structures are crucial for the long-term success and sustainability of family businesses.  Unlike public companies, family enterprises face unique challenges, including the intertwining of family dynamics with business operations.  Establishing robust governance structures—such as family councils, boards, and advisory committees—ensures that these businesses remain ...
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Developing Conflict Resolution Guidelines
Creating Formal Procedures for Family Businesses

Andersen 01/01/1970
In family businesses, personal relationships often amplify conflicts, making formal conflict resolution guideline or policies essential.  These guidelines separate personal from business issues, providing clear guidelines for managing disputes and preventing long-term damage.  Given the unique dynamics of family enterprises, conflicts can easily become personal. ...
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The member firms of Andersen in Canada focus on Canadian, international and Canada-U.S. cross-border tax matters. With offices across Canada, our tax professionals work with a broad range of businesses and individual clients to develop innovative tax solutions for a diverse range of issues. Our senior leaders and many of our professional staff have extensive experience in Canadian, international, U.S. and cross-border tax matters with major international accounting firms, as well as practical experience working with businesses and individuals.

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