Feigenbaum Law

voluntary disclosure program

A closed sign in a doorway

Personal Tax Planning

Key Amnesty Programs for US Taxpayers Living in Canada Set to Close

We have written in previous blogs about the increased lengths that the IRS and Canadian financial institutions are going to uncover dual US/Canadian citizens living in Canada who have failed to report US income tax. Some Americans living in Canada may have previously taken advantage of amnesty programs offered by the IRS such as the Offshore Voluntary Disclosure Program (OVDP) in order to file old income tax statements and avoid the potential financial penalties… Read More

Voluntary disclosure

Corporate Tax Planning

The End of IRS’ Voluntary Disclosure Program is Imminent

Earlier this year, the Internal Revenue Service (IRS) announced that it would begin to ramp down the 2014 Offshore Voluntary Disclosure Program (OVDP) and the program would be fully closed by September 28, 2018. The Offshore Voluntary Disclosure Program The OVDP initially launched in 2009, with a second program offered in 2011, and then 2012. The current program launched in 2014. These voluntary disclosure programs have enabled American taxpayers… Read More

Corporate taxes

Corporate Tax Planning

Changes Coming to CRA’s Voluntary Disclosure Program

The Canada Revenue Agency (CRA) has announced that, as of March 1, 2018, the Voluntary Disclosures Program (VDP) will be revised. The revisions narrow the eligibility for access to the Program and impose extra requirements on applicants. What is the VDP? As we’ve mentioned in a previous blog, the VDP is a program that gives taxpayers who have been non-compliant with filing or paying taxes a… 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