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2025 US Tax Reform – Proposed Section 899 is toxic

On May 12, 2025, the House Ways and Means Committee released the legislative text of the tax title of the Republican bill entitled “The One, Big, Beautiful Bill.” The bill was passed by the Ways and Means Committee and is moving forward. The final shape of the bill is...

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An Update on the NIIT Foreign Tax Credit

In an article published on October 24, 2023, we canvassed the unsettled landscape for Canadian-resident US citizens to claim foreign tax credit against their US Net Investment Income Tax (the “NIIT”) under the U.S.-Canada Treaty (the “Canada Treaty”). There have been...

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Will John Tavares have Double Tax Trouble?

NHL player John Tavares’ well-publicized litigation pending before the Tax Court of Canada  demonstrates the principle that resolving cross-border tax disputes in a purely domestic fashion can be problematic. The facts of the case are straightforward and worth...

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US LLCs Cause Canadian Tax Problems

The limited liability company (“LLC”) is a very common US business entity that unfortunately can cause Canadian tax problems for its owners. These problems primarily arise from a fundamental difference in how many LLCs are taxed in the US and Canada. For a Canadian...

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An Update on Form 3520 + 3520-A for the TFSA

The resolution of three recent cases at the IRS Independent Office of Appeals support our longstanding view that no Form 3520 or 3520-A are required to report a TFSA to the IRS. As background, last year the IRS released guidance that exempted taxpayers from filing...

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Foreign Life Insurance for US Taxpayers

In the previous installment, we discussed the potential Canadian tax problems when a Canadian tax resident purchases a US life insurance policy. In this installment, we examine the same scenario in reverse – what happens when a US taxpayer purchases a Canadian life...

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US Life Insurance for Canadians

Many Canadians own some form of life insurance on the assumption that the insurance would provide tax-free funds to support their beneficiaries. While this is generally true, complex tax rules can lead to a different result in the cross-border tax context. What is...

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Questions?

If you’re looking for more clarity in your cross-border tax situation, contact Max Reed at
+1-604-283-9301 or via email at max@polaristax.com to find out how we can help you.