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Cross-Border Tax Newsletter

Subscribe to our newsletter and stay up-to-date on developments in cross-border tax issues that may affect you, your clients or your players.

Potential Tax Legislative Developments in the U.S. Under the Trump Presidency

With the new administration starting this month there may be tax changes on the horizon.  The Presidency, House and Senate all have majority Republican control.  However the tax plans for the different branches are different and some censuses must be obtained for anything to pass through the legislative system.

Mark Feigenbaum, CPA, CA


IRS Blocked From Taxing Prizes & Awards for Some Olympic Athletes in the U.S.

 H.R. 5946 which was recently signed into law by President Obama and its impact on the U.S. taxation of prizes and awards for Olympic Athletes.

Mark Feigenbaum, CPA, CA


The Price of Success: Cross-Border Taxation for Professional Athletes

With the sports free agency season in full swing, decisions and choices will be made on contract offers based in part on the tax implications.  As most of the leagues play both in Canada and the United States, cross-border tax planning is front and center.

Mark Feigenbaum, CPA, CA


Surface Transportation and Veterans Health Care Choice Improvement Act

The President signed a Bill on July 31 with not much fanfare. The Surface Transportation and Veterans Health Care Choice Improvement Act of 2015 was signed into law and otherwise wouldn’t give much indication that there were a number of tax provisions buried in a law which extends transportation spending and deals with Veterans issues.

Mark Feigenbaum, CPA, CA


Tax Inversions: Burgers & Coffee

Tax inversions have been front and center in the news recently, hitting close to the homes of many Canadians with the December 2014 transaction between Burger King and Tim Hortons. The attention has provided an opportunity to discuss corporate taxation, specifically tax inversions, in Canada, the United States and around the world.

Mark Feigenbaum, CPA, CA


An analysis of US State Taxation applied under the Canada-US tax treaty

When consulting on cross-border taxation we often just analyze federal taxation in both Canada and US. Practitioners typically look at the combined provincial and federal rates in Canada, compare or add it to the US federal rates, and calculate the offsetting foreign tax credits to create a total worldwide tax rate.

Mark Feigenbaum, CPA, CA


2013 US Tax Structure: Impacts For Canadian Residents

Beginning January 1, 2013 a number of new taxes and new rates took effect in the US tax system. Tax rates, on occasion, change in the US and for the most part don’t affect Canadians or US citizens living in Canada. However, with this round of tax changes Canadian residents should take note.

Mark Feigenbaum, CPA, CA


The Proposed Marketplace Fairness Act for Internet-Based Businesses

A bill is making its way through Congress that will substantially alter the internet sales landscape if it becomes law. The Marketplace Fairness Act which has been lobbied by retailers for some time, has now passed through the Senate and making its way to the House of Representatives where it is expected to be met with some resistance. By way of background, the current rules and decisions of the courts state that an online merchant who sells goods to a purchaser in a state where they do not have a physical presence do not need to charge sales tax on that purchase.

Mark Feigenbaum, CPA, CA


Photo Finish for The Fiscal Cliff Hanger

In what would be considered a photo finish in the sport of politics, the House of Representatives passed a version of new tax legislation that the Senate had already agreed to. The President could sign this Bill into law very early in the New Year.

Mark Feigenbaum, CPA, CA


Give and Take: US Tax Treatment of Gifts

This edition will discuss a US tax issue that is remarkably different from Canadian tax law. The subject of gifts both giving and receiving is fairly straightforward in Canada, but causes quite a discussion in the United States. Remember if there is a tax treatment different in Canada or the US than the other country, therein lies the opportunity for double taxation or taxation in one country without an offsetting foreign tax credit.

Mark Feigenbaum, CPA, CA


New US Offshore Voluntary Disclosure

The US has announced they are offering a new amnesty type program for international non filers called the 2011 Offshore Voluntary Disclosure Initiative (IR-2011-14). They feel that they were very successful with the last 2009 voluntary initiative, through which they claim to have received 15,000 disclosures.

Mark Feigenbaum, CPA, CA


What Dual Citizens Should Know About the US Principal Residence Exemption

With the ongoing difficulty of trying to apply one country’s tax laws to another country, practitioners should note that some of the common tax advice given to clients may not apply when that client is also a dual citizen. An outstanding example of this is the principal residence exemption in Canada.

Mark Feigenbaum, CPA, CA


The More Things Change the More They Stay the Same - The Tax Relief Act of 2010

The tax legislation negotiations went to the wire in December with drama worthy of a political television miniseries. There was speculation that the entire economy would collapse if Congress recessed without passing legislation to replace the expiring temporary legislation enacted by G. W. Bush, as several congress sessions and two presidential administrations had no success in seeking permanent legislation.

Mark Feigenbaum, CPA, CA