As the U.S. tax reform process continues, the comprehensive tax bill that passed the House of Representatives in May is now under active consideration in the Senate. Earlier this week, the Senate Finance Committee released...more
6/23/2025
/ Base Erosion and Anti-Abuse Tax (BEAT) ,
Digital Services ,
Diverted Profits Tax ,
FIRPTA ,
Foreign Investment ,
Foreign Tax ,
GILTI tax ,
Income Taxes ,
International Tax Issues ,
Investors ,
Multinationals ,
Proposed Legislation ,
Retaliatory Tariffs ,
Senate Finance Committee ,
Tax Rates ,
Tax Reform ,
U.S. Treasury
Canadians who emigrate to the United States or elsewhere face many decisions and considerations associated with departure, but careful tax planning should not be an afterthought. When an individual ceases to be resident in...more
2/4/2025
/ Canada ,
Estate Planning ,
Foreign Investment ,
Income Taxes ,
International Tax Issues ,
Partnerships ,
Property Owners ,
Real Estate Investments ,
Real Estate Transactions ,
Tax Liability ,
Tax Planning
In a historical opinion in Loper Bright Enterprises v. Raimondo, Secretary of Commerce, released at the end of June, the U.S. Supreme Court overturned the “Chevron” doctrine, which for so long had controlled judicial review...more
7/25/2024
/ Administrative Procedure Act ,
Chevron Deference ,
Federal Trade Commission (FTC) ,
IRS ,
Judicial Authority ,
Judicial Review ,
Loper Bright Enterprises v Raimondo ,
SCOTUS ,
Securities and Exchange Commission (SEC) ,
Statute of Limitations ,
Statutory Interpretation ,
U.S. Treasury
In prior bulletins from February 2023 and December 2022, we described a notice from the Internal Revenue Service (IRS) that outlined the rules that the IRS intended to issue with respect to the 1% stock buyback excise tax....more
Non-U.S. investors are generally subject to U.S. federal income tax on gains from investments in private U.S. real estate investment trusts (REITs). Two exceptions (among others) are for investments in “domestically...more
As we settle into the new year, let’s take a moment to first consider last year’s tax developments and then take a look ahead to what 2023 might have in store for us.
Review of U.S. Tax Developments in 2022-
In 2022 we...more
With another new year nearly upon us, we call attention to regulatory changes to the Stock Buyback Excise Tax that will be proposed to take effect on January 1 and the implications on more non-U.S. corporations. Specifically,...more