Jan. 30, 2020 - In our annual Tax Review and Outlook report, we look back at significant developments that shaped the Canadian and U.S. tax landscapes in 2019 and offer our predictions on what to expect in the year ahead. Key Canadian Developments in 2019 Proposed changes to the employee stock option rules...
Foreign Banks and Canada’s CFC System
Originally published in Tax Notes International, this article examines the Tax Court of Canada’s CIT judgment, as well as two pending companion cases, and sheds light on how the simple notion underlying controlled foreign corporation attribution rules— that CFCs’ undistributed passive income should be taxed as earned — can evolve into complex, mechanical, and sometimes convoluted rules.
Jan. 30, 2020 - Review of U.S. Tax Developments in 2019 In 2019, the U.S. tax world continued to be primarily concerned with developing guidance under the monumental Tax Cuts and Jobs Act (TCJA), which was enacted at the end of 2017. Major regulatory projects were proposed beginning in 2018,...