IRS Encourages US Citizens to Disclose

Recently the Federal Court of Appeal found that Canada's agreement requiring the CRA to disclose details of bank accounts held in Canada by Americans was not unconstitutional, and refused an application for a injunction to stop CRA from disclosing information pending further appeals. Now the IRS is urging United States citizens, including the nearly one million known to be living in Canada, to disclose their income and bank accounts under the US voluntary disclosure programs.  Read more.

Court Upholds Bank Disclosure to the United States

In 2010 the United States passed the Foreign Account Tax Compliance Act ("FATCA") imposing on non-us financial institutions the obligation to report to the US details of foreign bank accounts held by United States citizens and residents, whereever they might reside.  Under FATCA, foreign financial institutions faced the conundrum of complying with US law requiring disclosure, or the foreign domestic laws requiring confidentiality.

US Foreign Bank Account Reporting - Important Updates

The US requires its citizens (as well as green card holders) to annually report on each non-US bank account, including Canadian RRSP's and TFSA's. The penalties for non-filing and late-filing are significant.  Kevin Nightingale published this commentary on recent news about the FBAR requirements.

How to get a tax deduction for donations to U.S. charities

Our tax system offers generous benefits to donors who choose to make gifts to registered charities. Individuals can claim both federal and provincial tax credits worth up to 50 per cent of the amount donated, depending on your province of residence. Corporations can claim a deduction from their taxable income for qualifying donations.

Supreme Court upholds preparer penalties

The Supreme Court has upheld the so-called "preparer penalties under subsection 163.2 of the Income Tax Act as proper administrative penalties. In this matter, a lawyer who had been paid $1,000 for her legal opinion was fined $547,000 by the CRA for her role in issuing charitable donation receipts in a tax scheme organized by others. Refer to Guindon v.

Accountants' tax provision working papers open to CRA

Accountants providing opinions on corporate financial statements are required to consider whether the corporation has made adequate provision in its ac

CRA Owes a Duty of Care to Taxpayers

The Supreme Court of British Columbia, in a civil suit by a taxpayer against the CRA, held that the CRA owes a duty of care to taxpayers.  Jonathan Garbutt discusses this decision HERE

US FATCA Rules Implemented in Canada

Bill C-31 received Royal Assent on June 19.  Included in this bill were provisions effectively implementing in Canada the US requirements under FATCA (the Foreign Accounts Tax Compliance Act) requiring the reporting to the IRS by Canadian financial institutions about financial accounts held by US taxpayers in Canada.

Canada & U.S. To Track Taxpayer Time In Either Country

Beginning June 30, 2014, Canada and the U.S. will implement a new joint initiative to share information with each other about when individuals cross the Canada-U.S. border to enter and leave their respective countries. This initiative will allow both countries to accurately track the whereabouts of Canadian and U.S. persons who cross the Canada-U.S. border for business and/or personal reasons.  Natasha Miklaucic of Borden Ladner Gervais LLP explains in a recent article.

Bill C-31’s Serious Offences Amendment to Section 241 of the Income Tax Act

Taxpayers have cause for concern over proposed amendments to the Income Tax Act.  Buried in a recent 375-page omnibus bill, Bill C-31, is a provision giving Canada Revenue Agency officials the power to release taxpayer information to the police when, in their opinion, there a


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