Jan. 31, 2025 - First published by the Canadian Tax Foundation in (2024) 72:4 Canadian Tax Journal. Treaty Provides Unique Benefits To Canadians Migrating To The United States Canadians who emigrate to the United States or elsewhere face many decisions and considerations...
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Onerous US Reporting Requirements for US Members of Non-US Family-Controlled Entities: It’s All in the Family
Family wealth and business planning often gives rise to structures that come with burdensome reporting obligations for minority US shareholders. In this Canadian Tax Journal article, Davies partners Peter Glicklich and Gregg Benson point out some of the cases where the burden is much larger than it should be, requiring information that would not ordinarily be shared with the younger generation.
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Federal Court of Appeal Confirms CRA Can Collect Arrears Interest Despite Absence of a Tax Debt
Dec. 04, 2024 - The Federal Court of Appeal (FCA) recently dismissed the Bank of Nova Scotia’s (BNS) appeal and upheld the Canada Revenue Agency’s (CRA) practice of charging arrears interest on a non-existent tax debt where audit adjustments increase taxable income that is offset by the carryback of a loss...
