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...

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...

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” rules).