Individuals moving between Canada and the United States face a daunting array of Canadian and U.S. tax issues, particularly when the move is due to an employment-related transfer. This book provides an overview of key taxation principles related to employment both in Canada and in the United States, and highlights the interaction between the tax laws of these two countries. For employers, this book offers practical guidance on tax issues for the purpose of managing expatriate costs, designing an effective cross-border employee relocation program and retaining key employees.

Key Topics include:

• Overview of the Canadian and U.S. personal tax systems
• Tax reimbursement programs, including sample tax equalization calculations
• Foreign tax credits and tax relief available under the Canada-U.S. tax treaty
• The implications of changes under the fifth protocol to the Canada-U.S. treaty which entered into force on December 15, 2008
• Investments in partnerships, limited liability companies, and other entities
• Taxation of artists and athletes
• Estate planning, including U.S. estate tax issues
• Executive compensation, including various types of equity compensation and long-term incentive plans available
• Expanded discussion on the U.S. deferred compensation rules 

About the Author

Benita Loughlin, CA, is a Partner in the International Executive Services practice at KPMG LLP in Vancouver, B.C. She specializes in tax planning and compliance for individuals, estates and trusts in a U.S. and cross-border context. She advises executives and their employers on tax matters related to compensation, investments, retirement plans, estate planning, and expatriation, with emphasis on employees relocating to or from other countries. The book includes contributions from KPMG International Executive Services professionals in Vancouver who specialize in helping clients manage complex personal tax issues in a cross-border environment. KPMG’s multinational corporate clients face challenges managing tax issues that affect their global workforce. Executives and employees rely on KPMG’s international tax planning to help manage their tax liabilities and maintain their global workforce.

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Available: August 2011

Authors: Michael S. Schadewald, Ph.D., CPA and Robert J.Misey, Jr., J.D., MBA and LL.M.

Provides readers with a practical command of the tax issues raised by international transactions and how those issues are resolved by U.S. tax laws. The book emphasizes those areas generally accepted to be essential to tax practice.

The book is written primarily as a desk reference for tax practitioners and is organized into four parts.

Part I provides an overview of the U.S. system for taxing international transactions, and also discusses the U.S. jurisdictional rules and source-of-income rules.

Part II explains how the United States taxes the foreign activities of U.S. persons, and includes chapters on the foreign tax credit, deemed paid foreign tax credit, anti-deferral provisions, foreign currency translation and transactions, export tax benefits, planning for foreign operations, and state taxation of foreign operations.

Part III describes how the United States taxes the U.S. activities of foreign persons, including the taxation of U.S.-source investment-type income and U.S. trade or business activities, as well as planning for foreign-owned U.S. operations.

Finally, Part IV covers issues common to both outbound and inbound activities, including intercompany transfer pricing, tax treaties, cross-border mergers and acquisitions, and international tax practice and procedure.

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Non-Residents, Cross-Border Transactions, and the GST is an invaluable resource for anyone involved with GST/HST issues concerning non-residents. This book provides practical guidance for non-residents of Canada that deal with Canadian customers or products, or carry on business in Canada, and need to know how the GST/HST applies to them. Non-Residents, Cross-Border Transactions, and the GST is a useful addition to the library of anyone who deals with non-residents including commodity tax practitioners, controllers, and business owners.

Key topics discussed in the book include:

• Drop-shipments
• Non-resident override rule
• Place of supply rules
• Cross-border transactions
• Imports and exports
• De facto importer rules
• Permanent establishments and carrying on business in Canada
• Recovery of tax by non-residents

The book contains clear explanations of fundamental topics, with numerous examples, especially on the application of the tricky drop-shipment rules. Also contains a detailed topical index.

Steven K. D'Arcy is a lawyer and a partner in Bennett Jones LLP, one of Canada's leading business law firms. His practice involves all areas of commodity tax with particular emphasis on the goods and services tax, Canadian customs laws, provincial retail sales tax, and anti-dumping duties.

In his GST practice, Steven advises on all facets of the GST legislation with emphasis on corporate transactions, particularly cross-border transactions. He has represented clients on numerous occasions with respect to GST assessments and proposed assessments. Steven served as counsel to the House of Commons Standing Committee on Finance with respect to its review of alternatives to the GST and has frequently provided advice to the Department of Finance with respect to proposed GST amendments.

Steven was recently recognized as a leading Canadian tax practitioner in indirect taxes in the International Tax Review's World Tax 2005. He is annually recognized in LEXPERT®/American Lawyer's Guide to the Leading 500 Lawyers in Canada, is also recognized in LEXPERT's Canadian Legal Directory as one of Canada's most frequently recommended commodity tax/customs practitioners, and is consistently recommended as an international trade regulation practitioner. Steven co-developed the Canadian Institute of Chartered Accountants annual "In-Residence GST Course", and currently teaches Part II of the course. He is an editor of the CCH GOODS AND SERVICES TAX REPORTER and the monthly GST Monitor.

He lives in Oakville, Ontario with his wife Susanna and their three children, Charlotte, Polly, and Duncan.

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Available: August 2010

Authors: Marc M. Levey J.D., Steven C. Wrappe J.D., CPA

Transfer Pricing: Rules, Compliance and Controversy offers extensive yet clear guidance through the complex maze of U.S. transfer pricing rules. The book is authored by leading experts in the transfer pricing scene. Throughout the book, the authors cover all aspects of transfer pricing relevant to the practitioner, starting with general legal principles and apportionment methods, then moving on to more specific subjects such as transfers of tangible vs. intangible goods and the impact of e-commerce and U.S. customs on transfer pricing, and finally exploring highly practical matters like procedural strategies and post-examination procedures.  

The book's practical coverage and approach include:

• Comprehensive analysis of the U.S. rules, case law and guidance on  transfer pricing for tangible   goods, intangibles, and services
• Complex cost-sharing planning principles, including buy-in
• Cutting edge e-commerce transfer pricing issues
• U.S. penalty and documentation rules
• Documentation with checklists, questionnaires and model report
• U.S. penalty rules compared to those of other important countries
• Overlap between transfer pricing and Customs valuation issues
• Customs ruling based on an APA
• In-depth, step-by-step analysis of the favored approach to transfer pricing controversy, including:
  • Developing a substantive/procedural strategy (with detailed flow-chart)
  • Preparing for examination
  • Identifying post-examination opportunities to resolve the dispute

Special appendices provide a variety of "practice tools" designed to facilitate the understanding of the IRS' provisions and their translation into action, e.g., IRS forms, tables and charts of relevant cases, and comparisons of international transfer pricing rules within particular contexts.  

Table of Contents 

Chapter 1 - Introduction
Chapter 2 - General Principles of Code Sec. 482

• Arm's length standard
• Best method rule
• Comparability
• Arm's length range
• Determination of true taxable income
• Collateral Adjustments
• Transfer pricing and non-recognition provisions
• Blocked income

• Comparable uncontrolled price method (with cases applying this method)
• Resale price method
• Cost plus method
• Cost-plus method
• Comparable profit method
• Profit split method
• Unspecified methods

Chapter 4 - Methods

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Canadian Transfer Pricing describes and clarifies Canada's current transfer pricing rules. It sets out the methods used by the CRA and described in the OECD Guidelines for determination of an arm's length price for goods and services.



Due to the large dollar amounts involved in transfer pricing disputes, the importance of transfer pricing to the Canada Revenue Agency ("CRA") continues to evolve into a prominent component of tax collection and enforcement in Canada. Tax practitioners and company executives need to be aware of the procedures and documentation requirements in order to remain compliant with the transfer pricing rules and to be better prepared in the face of an audit by the CRA. This is also true for companies intending to establish an APA or resolve disputes with the revenue authorities in Canada and overseas with respect to transfer pricing transactions.

Authored by Jules Lewy, BCL, LLB and members of the tax group of one of Canada’s largest and most respected law firms, Dentons, Canadian Transfer Pricing provides a comprehensive overview of the Canadian transfer pricing regime.  This essential edition includes discussion on the OECD’s involvement in the area of transfer pricing tax policy as well as a brief overview of the U.S. transfer pricing legislation.



Chapters Include:

• What is Transfer Pricing?
• Transfer Pricing Rules Prior to 1999
• Canada’s Current Transfer Pricing Rules
• Transfer Pricing and Intra Group Services
• Transfer Pricing and Restructuring
• Contemporaneous Documentation and Transfer Pricing Penalties
• Advance Pricing Agreements
• Transfer Pricing Audit Process
• Transfer Pricing Dispute Resolution
• Competent Authority
• Jurisprudence
• Transfer Pricing and Customs, GST and HST.

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Offers extensive yet clear guidance through the complex maze of U.S. transfer pricing rules. The book is authored by leading experts in the transfer pricing scene. Authors cover all aspects of transfer pricing relevant to the practitioner, starting with general legal principles and apportionment methods, then moving on to more specific subjects such as transfers of tangible vs. intangible goods and the impact of e-commerce and U.S. customs on transfer pricing, and finally exploring highly practical matters like procedural strategies and post-examination procedures. 

• Comprehensive analysis of the U.S. rules, case law and guidance on  transfer pricing for tangible goods, intangibles, and services
• Complex cost-sharing planning principles, including buy-in*
• Cutting edge e-commerce transfer pricing issues
• U.S. penalty and documentation rules
• Documentation with checklists, questionnaires and model report
• U.S. penalty rules compared to those of other important countries
• Overlap between transfer pricing and Customs valuation issues
• Customs ruling based on an APA
• In-depth, step-by-step analysis of the favored approach to transfer pricing controversy, including:
  • Developing a substantive/procedural strategy (with detailed flow-chart)
  • Preparing for examination
  • Identifying post-examination opportunities to resolve the dispute

Special appendices provide a variety of "practice tools" designed to facilitate the understanding of the IRS' provisions and their translation into action, e.g., IRS forms, tables and charts of relevant cases, and comparisons of international transfer pricing rules within particular contexts. 

Table of Contents (Summary)
Chapter 1   Introduction
Chapter 2   General Principles of Code Sec. 482
Chapter 3   Methods for Transfers of Tangible Property
Chapter 4   Methods for Transfer of Intangible Property
Chapter 5   Intercompany Services
Chapter 6   Intercompany Loans and Advances
Chapter 7   Penalties
Chapter 8   The Code Sec. 1059A limitation
Chapter 9   Overall strategy for compliance and controversy
Chapter 10  Preparing transfer pricing documentation
Chapter 11  Examination
Chapter 12  Post-examination procedural alternatives
Chapter 13  Advance pricing agreements
Chapter 14  The OECD approach to transfer pricing
Chapter 15  Customs valuation issues
Chapter 16  State transfer pricing

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Schwarz on Tax Treaties, 3rd E

If you would like more details about this product, or would like to order a copy online, please click here.

Authors: Michael S. Schadewald and Robert J. Misey, Jr.

Provides readers with a practical command of the tax issues raised by international transactions and how those issues are resolved by U.S. tax laws. The book emphasizes those areas generally accepted to be essentialto tax practice.

PART I: BASIC PRINCIPLES OF U.S. TAXATION OF INTERNATIONAL INCOME

• Overview of U.S. Taxation of International Transactions
• Tax Jurisdiction
• Source of Income Rules

PART II: TAXATION OF FOREIGN ACTIVITIES OF U.S. TAXPAYERS

• Foreign Tax Credit
• Deemed Paid Foreign Tax Credit
• Anti-Deferral Provisions
• Foreign Currency Translation and Transactions
• Export Benefits
• Planning for Foreign Operations
• State Taxation of Foreign Operations

PART III: TAXATION OF U.S. ACTIVITIES OF FOREIGN TAXPAYERS

• Foreign Persons Investing in the United States
• Foreign Persons Doing Business in the United States
• Planning for Foreign-Owned U.S. Operations

PART IV: TAXATION ISSUES IMPACTING BOTH U.S. AND FOREIGN TAXPAYERS

• Transfer Pricing
• Income Tax Treaties
• Cross-Border Transfers and Reorganizations
• International Tax Practice and Procedure

Appendices provide reproductions of applicable IRS forms and publications, as well as the latest U.S. Model Income Tax Treaty.

688 pages

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It's often a very difficult decision for your client to make, when they must decide whether to transfer holdings in their farm or farm property. But the complexity doesn't end there. While that decision is being made, the advisors must step in and help to ensure that the transactions are arranged in the most tax efficient and practical manner. For those approaching any potential farm restructurings or sales, this webinar will be essential.

This archive webinar covers a comprehensive look at the preferential tax treatment that transfers of qualifying farms or farm property can enjoy on passing to the next generation or on the sale to outside parties. This includes an overview of the capital gains exemption available for the sale of qualifying farm property shares and partnership interests, and rollovers to certain family members (both inter vivos and on death). While similarities do exist with among these transfers, there are traps and nuances that practitioners must be aware of to ensure their transactions qualify for beneficial tax treatment desired.

More specifically, for each of the above types of transfers, this archived webinar will explore:

• What property qualifies for the treatment?
• Who is entitled to the preferential tax benefit?
• What does farming mean in these contexts?
  • What is the business of farming for tax purposes?
  • What is being "actively engaged on a regular and continuous basis"?
  • Who must farm the property?
  • When must farming activity take place?
  • How much of the property must be used in farming?
• What are the common things farms may do to fall offside?
• Putting it all together - a compare & contrast with examples
• Bonus Issue (time permitting) - Craig vs. the Queen - restricted farm losses

Note: This webinar took place on October 1, 2013.

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By popular demand, we are now offering an archived version of the webinar GST/HST & Real Property Transactions that took place on November 20, 2014.
 
Although many GST and HST concepts are well understood by taxpayers, many of the real property rules are less well known. The rules associated with real property are complicated, having led even tax practitioners astray, and the dollar values of these transactions are usually high. Accordingly, audit activity in the sector is also high and GST/HST errors have led to costly CRA reassessments.

This archived webinar will provide a practical understanding of the complex rules for real property transactions and the current issues faced by the industry in applying the GST/HST in the development, construction and sale of real property.

Topics specifically covered include:

• Current state of affairs
• Bare trustees
• Joint ventures
• Partnerships
• Sales of vacant land
• Self-assessments
• New housing rebates
• Rental property rebates
• Documentary requirements for input tax credits

By purchasing this archive webinar, you will receive:

• 30 days to review the webinar recording 

• PDF version of the presentation slides

Our Speaker: 

Wayne Mandel, PwC LLP

Wayne Mandel is an Indirect Tax Manager with PricewaterhouseCoopers LLP. He specializes in the Goods and Services Tax and the Harmonized Sales Tax and has concentrated his area of practice primarily in the real estate sector. Wayne has provided advice and interpretation on a wide range of issues and has also provided assistance to clients in preparing for government audits, support during the audit process and resolving assessment issues. Wayne has experience in the appeals process and making submissions under the government's taxpayer relief provisions. He has delivered numerous presentations to clients on changes and new developments in these taxes.

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Rotch Library - NA1540.F82513 2017

Rotch Library - NA21.V47 2019

Rotch Library - NA2500.K8613 2019

Rotch Library - NA680.P45 2018

Rotch Library - NA2543.N48 M4813 2018

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Rotch Library - SB471.M8513 2018

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Rotch Library - NA7880.V56 2019

Just when you thought you could delete us from your podcatcher we are back and with a distinct lack of excuses for our absence. This week we discuss our new weekly formats and chat extensively about “transitioning”.

Over the last few months both of us have found our main focuses shifting and as a result the way we present ourselves online has changed, or had to change, too. We revisit our discussion on “flowery Twitter bios” and look at ways in which our friends, colleagues and heroes represent themselves online – through the blog posts they write, links they curate and share and other output including podcasts and videos. We touch on expectations, schedules and much more in our first episode back behind the Yeti’s.

• Sean Wes
• The Sean Wes Podcast: Episode 92
• Daniel Howells on Twitter
• Gary Vee
• Gary Vee on YouTube

We’d love to hear about your experiences of transitioning. Get in touch on Twitter and Facebook.

Darvill, Angela, author