<p class="p1">Many businesses use stock options to attract and reward good employees. Stock options give employees the opportunity to share in the future growth of a company without reducing the company’s cash flow. If the stock options are structured properly, the employee can enjoy the benefit on a tax-effective basis. 

<p class="p1">It appears that every week the news media informs us that another major company has been hacked. The latest big-name victims are Ashley Madison, the online dating and social networking service marketed to people who are married or in a committed relationship, and the Excellus health insurance system. The Ashley Madison data breach resulted in the release of the email addresses and other personally identifiable and sensitive information of millions of people who had registered on the website. As a result, Ashley Madison has already been hit with more than half a billion dollars in lawsuits, threatening the financial stability of the company. The impact on Excellus is not yet known. 

According to the United States Treasury Inspector General for Tax Administration (TIGTA), U.S. taxpayers have reported more than $20 million in financial losses resulting from IRS scam artists since October 2013. About 4,000 individual taxpayers have been affected. During the same period, TIGTA received over 600,000 reports of taxpayers being approached by likely scammers.

<p class="p1">We have noted previously in this space that lawyers today face the erosion of their services as clients restrict their legal budgets and as paralegals and other non-lawyer providers step up their forays into traditional legal services. Lawyers Alert contributor Gerry Riskin notes the impact of such non-lawyer providers on how firms must view their futures in the industry [“<span class="s1"><a href="/en/cbn/publications/illuminating-the-future" target="_blank">Illuminating the Future</a>,”</span>]. Some new tech tools appear poised to delve even further into that crossover.

<p class="p1">Today, speakers, writers and consultants in our field are besieged with questions about the impact of change on every aspect of the legal profession. Law societies, bar associations, corporate legal departments, private practice law firms and sole practitioners alike all want some expert to illuminate for them the mysterious path into the future. 

<p class="p1"><strong>First, see if it can answer “yes” to one essential question. </strong> <p class="p2">So law firm mergers are back in the news again, to the continued fascination of the legal press. For every combination that is completed and announced, you can count on several others bubbling under in conversations within executive committees and at luncheon gatherings of senior partners, so there likely will be more such deals announced through the balance of the year. 

This article is the third in a series of four examining the Canadian and U.S. income tax implications of the temporary assignment of an employee from Canada to the U.S. Specifically, these articles address the situation of an employee remaining employed by a Canadian entity, but temporarily assigned to work in the U.S. Our previous two articles (Winter 2015 <em>U.S. Tax Alert</em> and Spring 2015 <em>U.S. Tax Alert</em>) examined the importance of the determination of “residency” for personal income tax purposes, and the Canadian and U.S. personal tax liabilities based on different residency scenarios.

When a farmer decides it is time either to sell farm land or to transfer it to a child, the <em>Income Tax Act</em> can be a powerful ally. Sheltering a sale of farm land by using the capital gains exemption or the inter-generational rollover of farm land to a child can help the taxpayer move the land on a tax-deferred or tax-free basis. It is important, however, to be aware of all the rules associated with these strategies, as small details within the <em>Income Tax Act</em> can cause undesired consequences.

<a href="/" target="_blank"><em>Collins Barrow</em></a><em> is an independent member of </em><a href="http://www.bakertillyinternational.com" target="_blank"><em>Baker Tilly International</em></a><em>, the world’s eighth largest accounting and business advisory network by combined fee income of its independent members. It is represented by 161 firms in 137 countries.</em> 5 October 2015, will be remembered as one of the most significant dates in the history of international taxation, for it was when the Organisation for Economic Co-operation and Development (OECD) concluded its two-year base erosion and profit shifting (BEPS) project with the <a href="http://www.oecd.org/tax/beps-2015-final-reports.htm" target="_blank">publication of the final package of measures </a>which, in the words of OECD Secretary-General Angel Gurría, represent “the most fundamental changes to international tax rules in almost a century”.

<p class="BasicParagraph"><span>This technical bulletin covers the various developments from July to September 2015. Collins Barrow regularly publishes Technical Bulletin for the general interest of its clients and friends to highlight the continually changing accounting and assurance standards, and the interpretations thereof, in Canada.</span>

Are you a minority shareholder in a company? If so, there’s a chance you may eventually find yourself in a dispute with the majority shareholder(s) who has more control.