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tax sheltering

Corporate Tax Planning

US Government Will Not Pursue Border Adjustment Tax

Canadian businesses have had a piece of good news in the recently announced “shared vision” for US tax reform, as the US government announces that it will not pursue a Border Adjustment Tax (“BAT”) as part of their broader tax reform efforts. Border Adjustment Tax will not be part of tax plan A small group of Republican leaders released a very brief, relatively undefined,¬†Joint Statement on Tax Reform late last week. Among other… Read More

Corporate Tax Planning

US Releases NAFTA Negotiation Goals

Last week, the United States Trade Representative (USTR) announced their NAFTA negotiation goals ¬†for the upcoming renegotiation process. In order to proceed under the “fast-track” process rules, these had to be presented to Congress for feedback before beginning formal discussions. Broad NAFTA negotiation goals do not disclose specific policies There are a number of details missing from the document released, and it has been criticized for being overly vague. Despite hyperbolic statements about the… Read More

Corporate Tax Planning

IRS Launches Form 1120-F Non-Filer Campaign

The IRS Large Business and International Division (“LBI”) is taking steps to, “redefine large business compliance work and build a supportive infrastructure inside [LBI],” through a series of campaigns aimed at resolving areas of compliance risk. Some of these campaigns will target cross-border businesses, including the Form 1120-F Non-Filer Campaign. What is the Form 1120-F Non-Filer Campaign? Any foreign company that is involved in US business or trade must file a US tax return,… Read More

Tax Disputes & Litigation

Case Commentary – MAP Transfer Pricing Settlement is Binding on CRA

Earlier this year, the Tax Court of Canada released reasons in the case of Sifto Canada Corp. v The Queen. This decision addresses the legal impact of a transfer pricing settlement under the Mutual Agreement Procedure (“MAP”) article of the Canada-U.S. Tax Convention (“Treaty”), and determined that the Canada Revenue Agency (“CRA”) is bound by an earlier MAP settlement that set the transfer price for the transaction. Sifto Canada Corp. v The Queen The… Read More

Corporate Tax Planning

US Moves to Regulate Foreign Disregarded Entities

Efforts to fight cross-border tax evasion and other forms of international financial fraud are on the rise. As part of this effort, the US Treasury Department and Internal Revenue Service are making it more difficult for foreign entities to evade local taxes by increasing the compliance and reporting requirements for foreign disregarded entities. Tax evasion concerns associated with foreign disregarded entities The DRE enables a foreign entity to use a single owner LLC to hold… Read More