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 to be determined, and several broad-based […]| Polaris Tax Counsel
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 some changes since that article was published. Although the case law is not finally […]| Polaris Tax Counsel
| Polaris Tax Counsel
| Polaris Tax Counsel
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).| Polaris Tax Counsel
| Polaris Tax Counsel
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 these forms for the RESP and the RDSP, but that […]| Polaris Tax Counsel