Practical perspectives for contemporary legal challenges.
What happens to your estate if you are Canadian and your spouse is a U.S. citizen? What should each of you know before one spouse dies? Many cross-border couples have not considered how assets on both sides of the border will be treated when one of them dies or what the surviving spouse needs to …
Continue reading “Estate and Tax Planning for Cross-Border Couples: TFSAs and the IRS”
As global economies become increasingly interconnected via the internet, U.S. companies continue to enter into more international arrangements. As a result, U.S. companies are plunged into a complex maze of overlapping legal jurisdictions and heightened compliance requirements, increasing the risk of cross-border disputes. When a cross-border dispute is resolved by court order or by settlement …
Continue reading “Preventing Unexpected Tax Liability in Cross-Border Dispute Payments”
When it comes to federal tax deadlines, April 15th is at the top of everyone’s mind. It is a date nearly synonymous with the IRS. It is the date some look forward to (triggering a refund – yay!), and some dread (payment of tax – ugh). However, there is another deadline that is fast approaching …
Continue reading “July 10, 2026 – An IRS Deadline You Do Not Want to Miss!”
Section 168(n) Special Depreciation for Qualified Production Property As part of the One Big Beautiful Bill Act (the “OBBBA”), signed into law on July 4, 2025, Congress enacted a new provision under Internal Revenue Code Section 168, which permits taxpayers a 100% special depreciation allowance for qualified production property (“QPP”) used as an integral part …
Continue reading “Section 168(n): A New Opportunity for Expensing Qualified Production Property”
According to the National Taxpayer Advocate’s Annual Report to Congress, more than 155 million people filed their individual federal income tax returns electronically last year. That leaves more than 11 million people who filed their tax returns on paper. If you file via paper or make your tax payments via check, this tax blog is …
Continue reading “Don’t Blame USPS for Missing Your Filing or Payment Deadline!”
As a trust and estates and tax attorney, I am frequently asked by clients (and colleagues) if there are options to reduce the income tax burden they expect to pay on portfolio income or when they expect to experience a liquidity event in the future. Clients who live in high-tax states (e.g., states with a …
Continue reading “A Smart Way to Plan for High State Income Taxes: The Nevada ING Trust”
On July 4, 2025, President Trump signed the “One Big Beautiful Bill Act” (the “OBBB”), which makes a number of highly beneficial changes to the tax treatment of Qualified Small Business Stock (“QSBS”) acquired by “non-corporate” taxpayers after July 4, 2025. The goal of these changes is to encourage investment in new companies by providing …
The Employee Retention Tax Credit (“ERC”), enacted as a part of the Coronavirus Aid, Relief and Economic Security Act (“CARES Act”), is a fully refundable tax credit for employers, up to $26,000 per eligible employee. Because of the potentially significant value of the ERC to employers, the Internal Revenue Service (“IRS”) has warned of “blatant” …
When dealing with the Internal Revenue Service during the initial stages of a tax case, whether it involves an audit, collection issue, request for penalty relief, or a proposed plan of resolution such as an Offer In Compromise, taxpayers as well as tax professionals often overlook the right to resolution through the use of the …
On June 29, 2021, Bill C-208 was granted Royal Assent and became law in Canada. Bill C-208 amended the Income Tax Act (Canada) (the “Act”) to provide tax relief to families wishing to transfer shares of small business corporations, family farms, or fishing corporations to the next generation: their children and grandchildren. Ordinarily, the Act provides that …
Continue reading “Bill C-208: Intergenerational Business Transfers”