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Publications

Outbound Acquisitions: European Holding Company Structures [2012]

Published by the Practising Law Institute in the Corporate Tax Practice Series, 2012.

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Structuring International Operations Following 2010 Legislation

The 60th Tulane Tax Institute: October 26‐28, 2011.

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Governments and Information Gathering: Impact on MNE Planning

Published by Bloomberg BNA in the Tax Management International Journal, Vol. 39, No. 12: 2010.

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Understanding Your Neighbour

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As with most international tax planning, the key to cross-border Canada/US tax and estate tax planning is to synchronize the timing of the tax events and the taxpayer in order to minimize, and even eliminate, double taxation. Avoidance of tax in one jurisdiction may not be a satisfactory solution if it is merely a deferral or a shifting of a tax burden to a different taxpayer who or which may be subject ot tax at a lower rate (as well as a later time).

Canadian personal tax overview

Federal income tax is imposed on resident individuals, estates, trusts and companies based upon residency or domicile in Canada. Canada has an extensive array of dual tax treaties, so in many cases tax residency may be overidden by a treaty. If a resident, tax may be imposed on one's worldwide income, which, of course, is determined under specific definitions.

Tax Planning and Compliance for Foreign Businesses with U.S. Activity

Published 2009.

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Procedures Announced for Mandatory Arbitration under Germany-United States Tax Treaty

Published by the International Bureau of Fiscal Documentation (IBFD) in the Bulletin for International Taxation, Tax Treaty Monitor: April 2009.

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Practice Exposures for the International Tax Professions in the 21st Century

Published in the Tax Management International Journal, Vol. 37, No. 8: 2008.

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Tax Concepts Affecting the Foreign Entertainer or Athlete Performing in the United States

Published in the Tax Management International Journal, Vol. 37, No. 5: 2008.

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Hybrid Entities in Cross Border Transactions: The Canadian Experience - The U.S. Response [2008]

Published by the Practising Law Institute (PLI) in the Partnership Tax Practice Series: Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances, 2008.

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Pre-emigration with a Focus on United States

The 19th Annual International Trust & Tax Planning Summit: October 17, 2007.

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Home Thoughts From Abroad: Foreign Purchases of U.S. Homes

Published in TAX NOTES Tax Analysts Special Report, September 2007.

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Preimmigration Income Planning and Ethical Issues in Representing the Foreign Individual

New York University Summer Institute, International Taxation: 2007.

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Cross-Border Canadian-U.S. Planning

Published by ALI-ABA in The Practical Tax Lawyer, Volume 19, Issue 2: 2005.

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Economic Substance Around the World

Joint Meeting of the American Bar Association – Section of Taxation: May 2004.

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Recent Developments in U.S. Tax Law Affecting International Transactions

American Bar Association – Section of Taxation's Foreign Lawyers Forum: December 2003.

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Inbound Update: Increasing Attention by the I.R.S. to Foreign Taxpayers Doing Business in the U.S. [2002]

New York University Summer Institute, International Taxation: 2002.

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Exchange of Information

Step 2002 National Conference.

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Inbound Update: Increasing Attention by I.R.S. to Foreign Taxpayers Doing Business in the U.S. [2001]

New York University's School of Continuing and Professional Studies, Advanced Topics in International Taxation: 2001.

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Inbound Update: Increasing Attention by I.R.S. to Foreign Taxpayers Doing Business in the U.S. [2000]

New York University's School of Continuing and Professional Studies, Advanced Topics in International Taxation: 2000.

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