Oct. 04, 2019 - In SLFI Group v Canada (2019 FCA 217), the Federal Court of Appeal (FCA) overturned a Tax Court of Canada (TCC) decision and ruled that a group of Canadian mutual funds (Funds) was not required to self-assess GST/HST on funding services provided by a U.S. entity, because these services were...
Presentation: New IRS Partnership Audit Rules for Tax Counsel: Preparing for Massive Changes
This presentation discusses the far-reaching aspects of the new partnership audit rules provided by the Bipartisan Budget Act of 2015 and how this legislation will affect the formation and operations of partnerships, as well as the disposition of partnership interests and admission of new partners. Heath Martin presented this as part of an expert panel that provided a critical look at the impact of this law. His presentation offers insights on how to address changes brought about by the new audit processes and identifies commercial and operational concerns arising from the legislation.