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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.
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IRS Amnesty Programs Are Closing Soon. What You Need to Know.

January 23, 2020
In 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.
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U.S. Federal Income Tax and Information Reporting Relief Procedures for Certain Former U.S. Citizens

January 21, 2020
On September 6, 2019, the Internal Revenue Service (“IRS”) announced new U.S. tax relief procedures for certain former U.S. citizens.
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“Just Phoning It In,” Is Not Due Diligence For Directors

December 1, 2019
Recent 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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