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
by Max Reed Many high-net-worth Canadians have a significant portion of their net worth tied up in Canadian corporations due to the tax deferral and other benefits these structures provide. Additionally, many of these families have beneficiaries who are US taxpayers (either US citizens resident in Canada or US residents). This situation—lots of value in […]| 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
In the April 15, 2024, edition of Tax Notes International, Max Reed explains how the decision to front-load a signing bonus by an NHL player moving from a U.S. to a Canadian team saved him upfront Canadian tax but did not help his overall tax situation. You can read the full article here in PDF […]| 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
In the October 2020 edition of Benefits and Pensions Monitor, Max Reed outlines the modern realities of U.S. withholding taxes for pooled fund investments, and how a variety of Canadian organizations can claim refunds while preventing future losses. You can read the full article here in PDF format.| Polaris Tax Counsel
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 summaries such as this one are available.| Polaris Tax Counsel