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Final Regulations Partially Mitigate Overbroad Controlled Foreign Corporation Attribution Rules Passed as Part of 2017 U.S. Tax Reform
Despite new final tax regulations, U.S. taxpayers continue to deal with unexpected tax consequences of the overbroad rule change to the Controlled Foreign Corporation regime.
Lire la suiteIRS Amnesty Programs Are Closing Soon. What You Need to Know.
January 23, 2020In November 2019, the IRS confirmed its intention to close some of the IRS streamlined programs. Closure of these programs will affect your options if you have past U.S. federal income tax liabilities and filing delinquencies.
Lire la suiteU.S. Federal Income Tax and Information Reporting Relief Procedures for Certain Former U.S. Citizens
January 21, 2020On September 6, 2019, the Internal Revenue Service (“IRS”) announced new U.S. tax relief procedures for certain former U.S. citizens.
Lire la suite“Just Phoning It In,” Is Not Due Diligence For Directors
December 1, 2019Recent Tax Court of Canada ruling puts higher onus on directors of Canadian corporations to ensure employee and employer remittances are made.
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