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FBAR penalty – A welcomed decision by the Supreme Court
On Feb. 28, 2023, the U.S. Supreme Court ruled in Bittner v. United States that the non-willful penalty for failing to file the FBAR is assessed per report, not per account basis.
Mar 14, 2023
U S Tax Alert 48 AERIAL
Alert Transaction services Audit and accounting International
Borders without (tax) boundaries – Navigating U.S. returns in a cross-border setting
U.S. citizens and Green Card holders must file annual tax returns, even abroad. There are ways to reduce tax exposure, but failure to file can result in penalties.
Dec 13, 2022
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Alert Business advisory services Audit and accounting International
Addressing the proposed EIFEL rules
On Feb. 4, 2022, the Department of Finance introduced draft legislation for Excessive Interest and Financing Expenses Limitation (EIFEL) rules, based on OECD's BEPS Action 4 recommendations.
Mandeep Gaheer Nov 30, 2022
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Business advisory services Valuations International
Bored monkey or business model? Finding the commercial value in NFTs
Non-fungible tokens (NFTs) are evolving from buzzwords to business models, says Deepak Upadhyaya of Baker Tilly Canada, highlighting key considerations for brands looking to capitalize on them.
Deepak Upadhyaya May 4, 2022
Publications-Bored monkey or business model? Finding the commercial value in NFTs
Business advisory services Audit and accounting Private enterprise International
A streamlined procedure does not clear a GILTI conscience
The 2017 TCJA introduced a transition tax on accumulated earnings of foreign corporations, taxing active foreign income.
Nov 19, 2021
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Transaction services Private enterprise International Succession and estate planning
A hot housing market and a change in use equals tax with no cash. But there is a solution.
Most Canadians know that selling their home normally will not result in income tax thanks to the principal residence exemption (PRE). Unfortunately, people tend to extend this "knowledge" into a feeling that they need never worry about tax when dealing with their principal residence.
Eric Gagnon Jun 7, 2021
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Audit and accounting Private enterprise International Succession and estate planning
Who is more GILTI, Biden or Trump?
The Biden administration’s “Made in America Tax Plan” and what it could mean for U.S. citizens residing in Canada
Todd King Connor MacKenzie May 28, 2021
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Business advisory services Audit and accounting International Tax advisory
“Show me your papers, please”: zero-rated supplies of exported goods
The Excise Tax Act provides that generally, the supply of goods made in Canada is taxable for GST/HST purposes, and it is the responsibility of the supplier to collect the applicable GST/HST on taxable supplies.
Sep 17, 2020
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Audit and accounting International Tax advisory
IRS provides relief for U.S. citizens & residents with certain Canadian registered savings accounts
U.S. citizens and residents who own foreign trusts are often caught by the rules of the Internal Revenue Code section 6048, which requires those individuals to report transactions with, or ownership of, foreign trusts.
Mar 13, 2020
Turquoise waters washing up on a yellow sand beach with two people walking the coastline.
Audit and accounting International Tax advisory
U.S. citizens beware – IRS wants to know about your virtual currency
The U.S. government, along with most governments, has invested resources in understanding cryptocurrency and is developing policies to deal with virtual currency. As of today, Bitcoin still remains the most invested virtual currency on the market with a market cap of approximately $200 billion.
Mar 10, 2020
Turquoise waters washing up on a yellow sand beach with two people walking the coastline.
Business advisory services Audit and accounting Private enterprise International Tax advisory
Canadians doing business in the U.S.
​With the economy in Alberta the way it is, it is no surprise that oilfield workers are searching for business opportunities south of the border. But they and any other Canadians seeking to establish their business in the U.S. may not realize that there can be a lot of red tape to deal with. Proper planning is key before entering into this type of venture.
Nov 20, 2019
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