by Polaris Tax Counsel | Mar 8, 2024 | Cross-Border Tax, News
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...
by Polaris Tax Counsel | Oct 24, 2023 | Cross-Border Tax, News
For many US citizens who are resident in Canada, the Net Investment Income Tax (NIIT) is the only US tax they pay every year. Without a foreign tax credit or exemption, the imposition of the NIIT results in double taxation since the investment income is also subject...
by Polaris Tax Counsel | Aug 14, 2022 | Cross-Border Tax, News
Prepared by Max Reed, Polaris Tax Counsel and Tim Barrett, Thorsteinssons LLP In the April 2022 federal budget, the Canadian government proposed significant changes to the Canadian international tax rules (specifically the “foreign accrual property income” or “FAPI”...
by Polaris Tax Counsel | Jan 12, 2021 | Cross-Border Tax, News
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...
by Polaris Tax Counsel | Apr 14, 2020 | Cross-Border Tax, News
There are, by one estimate, 825,630 US citizens in Canada. Even if they owe no tax, nearly all are still supposed to file US federal income tax returns. Despite the penalty risk, many US citizens outside the US do not file US tax returns. To date, the consequences of...
by Polaris Tax Counsel | Mar 18, 2020 | Cross-Border Tax, News
The IRS has just announced limited relief for certain taxpayers due to the COVID-19 pandemic (Notice 2020-17). However, as currently drafted, this relief would not apply to US citizens or residents residing abroad. In particular, section III of Notice 2020-17 grants...
