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...

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...

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...