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International
Tax advisory
Planning for U.S. expatriation â The ins and outs of IRC 877A
The past several years have been a wild ride for many U.S. taxpayers (and tax practitioners), in particular for those residing outside of the country. While there are a surprising number of U.S. persons still grappling with becoming compliant, in general, the progression to considering expatriation has been somewhat predictable, as follows.
Todd King
Jun 10, 2016
International
Tax advisory
U.S. proposes new rules for related-party debt
On April 4, 2016, the U.S. Treasury Department and the IRS issued proposed regulations which govern whether certain related-party debt instruments will be classified as either debt or equity for U.S. federal income tax purposes. These rules are designed to prevent the excessive shifting of profits between related entities by way of interest charges on related-party debt instruments.
Jun 10, 2016
Audit and accounting
International
Transfer pricing
âSmallerâ multinational enterprises & transfer pricing
<h3>How saving $20K nearly cost this taxpayer $2.7 million!</h3> It seems that every day now there is an article of some sort addressing aggressive tax structures, often utilizing offshore entities, and the ramifications of (implied) inappropriate, underlying transfer pricing policies. Recently, this has clearly been due to the news of the âPanama Papersâ disclosure or, more generally over the past couple of years, the result of the recently finalized <a href="/en/cbn/publications/beps-the-final-reports-1" target="_blank">Base Erosion and Profit Shifting Project reforms published by the Organisation for Economic Co-operation and Development</a>.
Jun 8, 2016
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Farm businesses! Make the most of government funding
Due to the complexity of government subsidy and funding programs and the many steps involved in applying for them, farmers donât always take advantage of the opportunities available to them. In some cases, farmers who already rely on one program mistakenly believe that thereâs nothing else out there for them.
May 27, 2016
Transaction services
Audit and accounting
Revenue Recognition for Technology Companies for Multiple-Element Arrangements under IFRS 15
The International Accounting Standards Board (IASB) has published a new standard, IFRS 15 Revenue from Contracts with Customers (IFRS 15). IFRS 15 sets out requirements for recognizing revenue that apply to all contracts with customers and replaces the myriad of current revenue standards. This new standard is effective for annual reporting periods beginning on or after January 1, 2018.Â
May 25, 2016
Competitive Intelligence | Smart Phones
<em>âThis article was originally written for and published by the Financial Management Institute of Canada for the March 2016 edition of the fmi*igf Journal. Authored by <a href="/en/cbn/professionals/toronto-ontario/charan-kumar-bommireddipalli" target="_blank">Charan Kumar Bommireddipalli</a> of Collins Barrow Toronto LLP and <a href="/en/cbn/professionals/ottawa-ontario/leena-patel" target="_blank">Leena Patel</a> of Collins Barrow Ottawa LLP.â</em> Intelligence gathering has been an integral part of statecraft, so is information protection.
May 18, 2016
Audit and accounting
Private enterprise
Tax advisory
Infographic: Clamping down on small business deductions
Members of partnerships or shareholders (in certain corporate structures) â take note! The 2016 Federal Budget proposes to extend partnership income rules to certain partnership and corporate structures , which may: <ul> <li>limit your small business deduction on active business income (ABI) earned from the partnership or corporate structure, and</li> <li>increase your corporate tax liability </li> </ul>
May 17, 2016
Show, donât tell: effective leaders lead by example
In any business, leaders must find ways to inspire their team to deliver desired results. While telling them what to do might seem easier, itâs far more effective to lead by example.
May 10, 2016
Tax advisory
When measuring success, it pays to keep your distance
<strong>When measuring success, it pays to keep your distance</strong> Your business has stayed the course amidst untold degrees of uncertainty and persevered through the ups and downs. You have made significant sacrifices throughout this endeavour, bringing you to the very moment you are living today. But how well is your business really doing? Can you determine whether your business is successful or not?
Apr 27, 2016
Tax advisory
Canadian foreign reporting obligations
With the recent release of the International Consortium of Investigative Journalistsâ (ICIJ) investigation of offshore tax havens used by a law firm based in Panama (known as the âPanama Papersâ), the question of what Canada is doing to ensure that its taxpayers are disclosing offshore assets and reporting the related income is front and centre in the minds of many taxpayers.
Apr 22, 2016
Consider selling your business before 2017 â changes to eligible capital property rules
Entrepreneurs work hard at building their enterprise â but most of them want to eventually reap the rewards by selling all or part of their business. Entrepreneurs may focus on maximizing the purchase price through negotiation with a prospective purchaser, which is important. But they may be missing out on some important tax planning steps that can also have a significant impact on how much after-tax proceeds they can retain subsequent to the sale.
Apr 21, 2016
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