Published by the American Bar Association in the Real Property Trust & Estate eReport, February 2013.
Read MoreMembers of Ruchelman P.L.L.C. contribute to publications throughout the world and the Firm’s monthly tax journal, Insights.
Published by the American Bar Association in the Real Property Trust & Estate eReport, February 2013.
Read MorePublished by the Practising Law Institute in the Corporate Tax Practice Series, 2013.
Read MorePublished by the Practising Law Institute in the Corporate Tax Practice Series, 2012.
Read MoreThe 60th Tulane Tax Institute: October 26‐28, 2011.
Read MorePublished by Bloomberg BNA in the Tax Management International Journal, Vol. 39, No. 12: 2010.
Read MoreAs 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.
Published by the International Bureau of Fiscal Documentation (IBFD) in the Bulletin for International Taxation, Tax Treaty Monitor: April 2009.
Read MorePublished in the Tax Management International Journal, Vol. 37, No. 8: 2008.
Read MorePublished in the Tax Management International Journal, Vol. 37, No. 5: 2008.
Read MorePublished by the Practising Law Institute (PLI) in the Partnership Tax Practice Series: Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances, 2008.
Read MoreThe 19th Annual International Trust & Tax Planning Summit: October 17, 2007.
Read MorePublished in TAX NOTES Tax Analysts Special Report, September 2007.
Read MoreNew York University Summer Institute, International Taxation: 2007.
Read MorePublished by ALI-ABA in The Practical Tax Lawyer, Volume 19, Issue 2: 2005.
Read MoreJoint Meeting of the American Bar Association – Section of Taxation: May 2004.
Read MoreAmerican Bar Association – Section of Taxation's Foreign Lawyers Forum: December 2003.
Read MoreNew York University Summer Institute, International Taxation: 2002.
Read MoreStep 2002 National Conference.
Read MoreNew York University's School of Continuing and Professional Studies, Advanced Topics in International Taxation: 2001.
Read MoreRuchelman P.L.L.C. provides a wide range of tax planning and legal services for foreign companies operating in the U.S., foreign financial institutions operating ...