Archive for North America

EU & U.S. Sign “Umbrella” Agreement To Protect Personal Data

William Byrnes

The EU-U.S. Ministerial Meeting on Justice and Home Affairs, hosted by the Netherlands Presidency of the Council of the European Union, took place in Amsterdam.

Signing of the “Umbrella” agreement represented a major step forward in EU-U.S. relations. The agreement sets high standards for the protection of personal data transferred by law-enforcement authorities.

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The Carbon Tax War

Annette Nellen

Well, it’s not a carbon tax war yet as neither side of this issue in Congress seems to have it as their number one issue. A carbon tax aims to increase the cost of using one type of fuel that leads to greenhouse gas (GHG) emissions and climate change. There are other types of GHG emission, but per the Environmental Protection Agency (EPA), carbon emissions represent 81% of the total.

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Antonin Scalia’s Legacy

TaxConnections Member Michael DeBlis

If any lawyers you happen to see this coming week look a bit more depressed than usual, it may be due, at least in part, to the unexpected passing of Supreme Court Associate Justice Antonin Scalia. His sudden death was especially jarring for all of us who have ever experienced the completely unanticipated loss of a friend or loved one.

The pride of Trenton, New Jersey passed away at age 79 while on vacation in Texas. He was a government lawyer for President Richard Nixon, and was subsequently appointed to the U.S. Court of Appeals. What’s the old joke…the definition of “federal judge” is a lawyer who knows a senator? From there, President Ronald Reagan appointed him to the High Court in 1986. Read more

Ideas for Retirement Savings Reform

Annete Nellen

On 1/28/16, the Senate Finance Committee held a hearing on – Helping Americans Prepare for Retirement: Increasing Access, Participation and Coverage in Retirement Savings Plans.  This isn’t the first time for this topic.  There were a few hearings on this in 2014. I’m not sure if anything is driving the renewed attention to this topic now.  While tax reform is challenging in an election year, this important topic seems good for any year.  There is a need for reform of the tax rules for retirement plans to make them more equitable and simple to help more people save for retirement. Read more





We are now almost half of the way through our 12 week special blog series. We hope you have enjoyed our work so far.

If you have missed out on each or any weeks blog so far, you can find them here: Read more

FLASH ALERT! WOTC: IRS Notice 2015-13: Providing Transition Relief For Employers Submitting Late WOTC Applications

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We Have Been Waiting For This!

The IRS has released IRS Notice 2015-13, which provides transition relief given the late retroactive renewal of the Work Opportunity Tax Credit program in December 2014. Notice 2015-13 waves the 28-day deadline for submitting IRS Form 8850 (the WOTC Pre-screen Notice) for qualifying employees hired in 2014.  The extended deadline for submitting the applications for affected employees is now April 30, 2015.

From the Notice:


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Kentucky Department of Revenue – Secrets Revealed

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Many states, like my home state of Florida, have broad freedom of information laws. Known in Florida as the Sunshine Laws, the state’s citizens can request a wide range of information from the government. Under the laws, so long as the information is not made confidential by a specific statute/law, then the government has an obligation to provide the citizen with whatever is requested. As a state and local tax (“SALT”) practitioner, I often use this knowledge to my advantage. I often request documents and statistics from the state that I find beneficial to myself, my client, or my practice.

Other states have similar laws. In Kentucky, the Open Records Act gives its citizens a mechanism to request a broad spectrum of information from its government. Like many state agencies believe, the Kentucky Department of Revenue thought it was above the law. Read more

New Information on US – Canada Income Tax Treaty

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There are a LOT of people from Canada in Denver, Colorado where I spend the majority of my time as a student of the US tax code. Many dual citizens got stung by the reasonably new US FBAR tax laws and there were some tragic cases that filtered there way up to my desk. Having grown up in Wisconsin and consider myself a Minnesotan I truly believe that anyone hearty enough to live north of Lake Michigan has to be by definition a good spirit. I personally love most everything about Canada from the cold winters to the oxygen rich summers.

With that I write today to my Canadian friends and clients to inform them that the IRS recently updated Publication 597, Information on the United States – Canada Income Tax Treaty. This publication discusses a number of treaty provisions that often apply to U.S. Read more

Dear Mr. President… Why I Must Expatriate….

US and Canada

This letter was posted by Robert Wood on Forbes’ website. Robert is a US tax lawyer based in San Francisco, California. He received this letter in the course of his practice. I thought it was well worth passing on and have reproduced it in full:

“Dear Mr. President,

I am writing with a heavy heart as I, my husband, and our daughter are all seriously contemplating giving up our U.S. citizenship. We are doing this not to avoid paying U.S. taxes but because we strongly object to a system that is blatantly discriminatory and unfair to law-abiding Americans living outside the country. In addition, it has become too expensive, too difficult, and frankly, too frightening, to try to comply with all of the tax filing Read more

Canadians With US Rental Property – What Are The Cross-Border Tax Implications?

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Canadians earning income from US rental property can be fraught with unexpected tax problems, which could severely hurt their after-tax return on investment. It is important to consult a cross-border tax professional before the purchase to understand all the US and Canadian tax implications of owning US rental property and to make the best decision for their situation on the right structure to own and finance the purchase of US rental property.

This is the first of a series of articles on the cross-border tax considerations of investing in US rental property. If you are planning to purchase US rental property, you need to have some basic understanding of the following US and Canadian tax law before you can make a sound decision on how you should own and finance the purchase of US rental property. Read more

Why Does U.S. Congress And IRS Want A Canadian Cop?

Canadian Mountie Silhouette

“Imagine my surprise when I found out the United States considers me a criminal,” says a Canadian police officer who has been enforcing Canadian laws and protecting Canadians for more than three decades.

The American government considers that Canadian cop a criminal because he hasn’t filed tax returns with Internal Revenue Service (IRS) on his entirely Canadian earned and taxed income. He also hasn’t submitted Foreign Bank Account Reports (FBARs) to U.S. Financial Crimes Enforcement Network (FinCEN) on joint bank accounts held at his local Canadian bank with his Canadian wife.

He had no idea until recently that he was required to do so simply because he was born Read more

The Basics of Canadian “Departure Tax”

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When an individual, who was resident in Canada for tax purposes, ceases to be resident in Canada, there is generally a deemed disposition of assets owned by that individual at their fair market value. Any resulting deemed gain must be reported on the final tax return filed as a resident.

This is commonly called “departure tax”. However, unlike the kind of “departure tax” that is levied at some airports, there is no tax official in Canada waiting to collect it when the Canadian expat leaves. Rather, it is calculated and payable as part of the normal income tax filing.

This article will provide an outline of the key points in relation to the “Departure Tax”. Read more