What South Dakota v. Wayfair Means for Canadian Companies

Are you a Canadian company selling goods to US customers? If so, the Wayfair decision might drastically alter your US Sales Tax Exposure. The clear implication of the Wayfair decision is that there will likely be a mass rush of states adopting new sales tax laws that will mirror the far lower threshold of “economic nexus” that has been implemented by South Dakota.

US Taxation of Canadian E-Commerce: Two Different Approaches, Two Different Results

The internet has changed how business is conducted, especially in a cross-border context. The ease and relatively inexpensive access to the internet, the emergence of social media sites such as YouTube, and the proliferation of company websites that operate as virtual storefronts, has created business opportunities where none existed before

US Tax Reform Summary

On December 22, 2017, President Trump signed into law the Tax Cuts and Jobs Act (HR 1).  This legislation, which was passed through Congress strictly on party lines, has made a significant number of changes and modifications to existing US tax law.   Although the new tax law is getting an enormous amount of press coverage […]

how will the IRS catch me

How Will the IRS Catch Me?

How will the IRS catch me? Sticking your head in the sand and wishing your troubles away is never a sound tax strategy.  You may be surprised, though, as to how many US persons (i.e. US citizens, green card holders or resident aliens) continue to follow this path even after years of media attention on […]

US Section 385 Final and Proposed Debt Equity Rules: Some Breathing Room

US Tax Alert: The IRS finalized the proposed regulations issued in April 2016 with Final and Proposed Regulations issued on October 13, 2016, after receiving more than 200 comments and concerned letters from members of Congress.  They backed off some of their harsher, proposed rules, in some cases eliminating parts of the rule, providing additional […]

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Thinking of Leaving the US? Know the Expatriation Tax Rules

It’s no secret that many Americans living in Canada are unhappy with their U.S. tax compliance costs and information reporting burdens. For those that are voting with their feet and renouncing their U.S. citizenship(i) or terminating their long-term U.S. residency(ii) (“expatriating”), careful planning should be undertaken prior to expatriating to avoid costly surprises. A few […]