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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: October 2010

Author: Glenn R. Carrington

Tax Accounting in Mergers and Acquisitions gives in-depth, practical coverage of today's key issues in corporate acquisitions, dispositions, reorganizations, and restructurings from a transactional perspective. It will help your client:

1. Decide if the transaction should be taxable or nontaxable.
2. Structure the deal for the best results-stock or asset acquisition.
3. Achieve desired business objectives.

This book considers the tax accounting implications of structuring and restructuring transactions including those described in Code 351 (Transfer to Corporation Controlled by Transferor), 338 (Certain Stock Purchases Treated as Asset Acquisitions), 381 (Carryovers in Certain Corporate Acquisitions), 721 (Nonrecognition of Gain or Loss on Contributions to a Partnership), and 1001 (Gain or Loss on Disposition of Property). It discusses the rules relative to a taxpayer’s ability to carry over methods of accounting, to obtain audit protection through filing accounting method changes, to preserve favorable methods of accounting, to determine the effect of the transaction on any unamortized Code 481(a) adjustments (Adjustments Required by Changes in Accounting Methods), and to use the chosen structure as a means of achieving appropriate tax accounting objectives. In addition, it describes some of the most common types of accounting method exposure items that arise during the course of due diligence and some of the alternatives for mitigating exposure to the buyer. Furthermore, it describes the most significant anti-abuse rules that prevent taxpayers from unreasonably taking advantage of these provisions. Finally, it addresses some of the pitfalls that taxpayers should take into account in structuring transactions. In addition to updates of all rulings, cases and legislation, the 2010 edition contains a new chapter on Bankruptcy.

Chapter 1       Taxable and Tax-Free Acquisitions
Chapter 2       Basic Concepts in Deductibility and Capitalization
Chapter 3       Accounting for Restructuring Transactions under Code §351, 338, 381, 721, and 1001
Chapter 4       Treatment of Contingent Liabilities
Chapter 5       Treatment of Transaction Costs Prior to the Final Capitalization Regulations
Chapter 6       Final Capitalization Regulations
Chapter 7       Debt Modifications in Connection with Mergers and Acquisitions
Chapter 8       Original Issue Discount (OID) in Mergers and Acquisitions
Chapter 9       Amortization of Intangibles under Code §197
Chapter 10     Limitation on Loss Carrybacks — Corporate Equity Reduction Transactions
Chapter 11     Consolidated Return Tax Accounting Issues
Chapter 12     Tax Accounting Issues in Bankruptcies and Work-outs

Related Books:

• Full Article

Available: September 2011

Author: Dr. Leo Troy

Determine a company's true measure of performance and value. The comprehensive resource puts 50 comparative performance indicators at the practitioner's command and covers all of North America (U.S., Canada, and Mexico) using NAICS data. The Almanac provides financial information that is calculated and derived from the latest available IRS data on nearly 5 million U.S. and international companies. The Almanac gives you accurate performance data for 50 operating and financial factors in 199 industries.

Data for each industry is divided into 13 categories based on company size, so you'll find a precise benchmark against which to measure any company's performance. One quick glance at the appropriate field of business and company-size category and you've found the definitive starting point for competitive performance analysis. The Almanac provides competitive norms in actual dollar amounts for revenue and capital factors, such as net receivables, net property, inventories, total assets, portfolio income, and more. It then gives you important average operating costs in percent of net sales, including cost of operations, pensions and benefits, interest, and more.

The Almanac provides ratios for industry-wide results for inventory turnover, current assets to working capital, quick ratio, asset turnover, and others. It also provides other critical financial factors in percentages, including debt ratio, return on assets, and return on equity, and profit margin.

The Almanac of Business and Industrial Financial Ratios comes complete with a CD that contains a special Excel Spreadsheet Template that can be used to input data on a given company to see how a company compares with the data provided in the Almanac.

The book is organized by the following major industry sectors, which in turn cover 199 industries, including:

• Agriculture, forestry, fishing, and hunting
• Mining
• Utilities
• Construction
• Manufacturing
• Wholesale trade
• Retail trade
• Transportation and warehousing
• Information
• Finance and insurance
• Real estate and rental leasing
• Professional, scientific and technical services
• Management of companies (holding companies)
• Administrative and support and waste management and remediation services
• Health care and social assistance
• Arts, entertainment and recreation
• Accommodation and food services
• Other services (including repair and maintenance, automotive repair and maintenance, personal and laundry services, and religious, grant making, civic, and professional organizations)

 

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Available: September 2010

Author: Leo Troy Ph. D.

CCH's Almanac of Business and Industrial Financial Ratios is the first step in helping to determine a company's true measure of performance and value.  The comprehensive resource puts 50 comparative performance indicators at the practitioner's command and covers all of North America (U.S., Canada, and Mexico) using NAICS data. The Almanac provides financial information that is calculated and derived from the latest available IRS data on nearly 5 million U.S. and international companies. The Almanac gives you accurate performance data for 50 operating and financial factors in 199 industries.

Data for each industry is divided into 13 categories based on company size, so you'll find a precise benchmark against which to measure any company's performance. One quick glance at the appropriate field of business and company-size category and you've found the definitive starting point for competitive performance analysis. The Almanac provides competitive norms in actual dollar amounts for revenue and capital factors, such as net receivables, net property, inventories, total assets, portfolio income, and more. It then gives you important average operating costs in percent of net sales, including cost of operations, pensions and benefits, interest, and more.

The Almanac provides ratios for industry-wide results for inventory turnover, current assets to working capital, quick ratio, asset turnover, and others. It also provides other critical financial factors in percentages, including debt ratio, return on assets, and return on equity, and profit margin. 

The Almanac of Business and Industrial Financial Ratios comes complete with a CD that contains a special Excel Spreadsheet Template that can be used to input data on a given company to see how a company compares with the data provided in the Almanac.

The book is organized by the following major industry sectors, which in turn cover 199 industries, including:

• Agriculture, forestry, fishing, and hunting
• Mining
• Utilities
• Construction
• Manufacturing
• Wholesale trade
• Retail trade
• Transportation and warehousing
• Information
• Finance and insurance
• Real estate and rental leasing
• Professional, scientific and technical services
• Management of companies (holding companies)
• Administrative and support and waste management and remediation services
• Health care and social assistance
• Arts, entertainment and recreation
• Accommodation and food services
• Other services (including repair and maintenance, automotive repair and maintenance, personal and laundry services, and reli

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

  
  
  Full Article
  
  

Written from a Canadian perspective for Canadian IFRS practitioners

The comprehensive commentary of iGAAP: IFRS for Canada is unique in that it is Canadian. It is authored from a Canadian perspective for Canadian practitioners and it draws on Deloitte's global IFRS experience. Commentary is provided on each significant Standard, organized topically into chapters, and contains explanatory information, analytical discussions, and illustrative examples of the application of IFRSs.

New and updated commentary includes:

• Financial Instruments, reflecting new standard IFRS 9 and other recent amendments
• IFRS 1, First-Time Adoption of IFRSs
• Related Party Disclosures, Interim Reporting, and Presentation of Financial Statements and Share-based Payments
• 2010 Annual Improvements changes and other recent amendments to IFRSs
• Significant recent Exposure Drafts and anticipated developments, including commentary on Leases, Revenue Recognition, Deferred Taxes, Contingencies, Employee Benefits, Extractive Activities
• Practical implications of applying IFRS in a Canadian environment.

Contained in each chapter of commentary are three value-added features developed specifically for Canadian practitioners:

• First-time Canadian Readers Guide provides an overview of individual Standards from a Canadian perspective
• Summary of Major Differences between Canadian GAAP and IFRS highlights key areas of change for Canadian practitioners
• Implications for Canadian Preparers summarizes significant practical implications for Canadian practitioners upon transition

In addition, comments specific to Canada are separately highlighted throughout the content, as are interpretive commentary and examples.

About the Authors of iGAAP: IFRS for Canada

Dr. Peter Chant, FCA, is a partner in the National Assurance and Advisory group at Deloitte & Touche LLP. He is a former member and Chair of the Canadian Accounting Standards Board and was co-Chair of the CICA/FASB Task Force that developed the current Canadian and FASB standard on segmented information. He was also a member of the FASB's Task Force on Business Combinations that developed the FASB's current standard on that topic, and a member of the G4+1 Group of standard setters, which included the Chairs of the IASB, FASB and the Canadian Accounting Standards Board. He has published a textbook on advanced accounting in Canada, and was co-author of a research paper on account

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CCH Provides the critical explanation and analysis to help you make sense of federal tax provisions enacted in 2001 and 2003 that are scheduled to expire December 31, 2012, so you can plan, respond and advise with confidence.

This book provides you with timely and practical guidance on the impending sunset of the tax cuts and benefits originally enacted as part of the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA). Additionally, enhanced capital gains and dividends tax rates in the Jobs and Growth Tax Relief Reconciliation Act of 2003 (JGTRRA) and subsequent legislation will also sunset after December 31, 2012. CCH editors, together with leading tax practionners and commentators, have created a complete practical analysis, guidance, examples and planning tips.

THE IRC provisions impacted by the sunset provisions of EGTRRA and JGTRRA are arranged in Code section sequence with caution language. CCH also provides several special tables and lists to facilitate quick and thorough understanding of how the sunset works, impacts the IRC and how it affects taxpayers.

Complimentary Special report: www.cch.ca/Sunset

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

CCH Provides the critical explanation and analysis to help you make sense of federal tax provisions enacted in 2001 and 2003 that are scheduled to expire December 31, 2012, so you can plan, respond and advise with confidence.
This book provides you with timely and practical guidance on the impending sunset of the tax cuts and benefits originally enacted as part of the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA). Additionally, enhanced capital gains and dividends tax rates in the Jobs and Growth Tax Relief Reconciliation Act of 2003 (JGTRRA) and subsequent legislation will also sunset after December 31, 2012. CCH editors, together with leading tax practionners and commentators, have created a complete practical analysis, guidance, examples and planning tips.
THE IRC provisions impacted by the sunset provisions of EGTRRA and JGTRRA are arranged in Code section sequence with caution language. CCH also provides several special tables and lists to facilitate quick and thorough understanding of how the sunset works, impacts the IRC and how it affects taxpayers.

Complimentary Special report: www.cch.ca/Sunset

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

The University of Chicago Law School held its 64th Annual Federal Tax Conference at the business school’s Gleacher Center on a memorable date: 11/11/11. Published exclusively each year in the special March Issue of Taxes—The Tax Magazine are the papers presented at this prestigious conference.

• The Past and Future of the Foreign Tax Credit (By Philip R. West and Amanda P. Varma)
• PFICs (By Kimberly S. Blanchard) discussing the policy and purpose of the PFIC rules and suggesting ways in which the PFIC rules could be made more workable by IRS guidance.
• Mayo Deference Examined Under the Six-Year Statute of Limitations Cases—A Proposal for a Constitutionally Sound Allocation of Lawmaking Authority (By Irving Salem) discussing the proper role of judicial deference to the agency.
• Updating the Tax-Free Reorganization Rules—Attributes, Overlaps and More (By Michael L. Schler, Eric Solomon, Karen Gilbreath Sowell, Jonathan J. Katz and Gary Scanlon) analyzing tax-free reorganization rules.
• To Err is Human; to Rescind, Divine (By Philip B. Wright) examining the role of rescission and other remedies to retroactively alter the tax consequences of a prior transaction.
• The Mysterious Case of Disappearing Debt in Partnership Transactions (By Phillip Gall and Franny Wang) analyzing the five primary cases of disappearing debt in partnership transactions.
• Employee Benefits Corner (by By Elizabeth Thomas Dold and David N. Levine) covering all types of employee benefits, including qualified plans, IRAs, governmental plans, nonqualified deferred compensation plans, and health and welfare plans.
• The Estate Planner (By Lewis Saret) examining the tax and legal aspects of trusts and estates and significant current developments
• International Tax Watch (By Stewart R. Lipeles, John D. McDonald) looking at the world of tax beyond the U.S.
• Tax Practice (By William D. Elliott) focusing on tax practice and procedure issues.
• Tax Trends (By Mark Luscombe) keeping you up-to-date on the latest trends in the tax world.

Special Feature:

• Unwinding or Rescinding A Transaction: Good Tax Planning or Tax Fraud (by Sheldon I. Banoff). In the seminal 1984 article, Shelly examines when unwinding, rescission or substantial modification will be respected for federal tax purposes.

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

Please purchase the latestd edition.

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Authors: Robert S. Keebler, Peter J. Melcher, MIchelle J. Ward, and Christopher W. Schuler

This new title analyzes the new 3.8% Medicare Tax on Net Investment Income, which will become effective January 1, 2013 pursuant to the Affordable Care Act of 2010 as recently upheld by the U.S. Supreme Court. This tax will have a wide ranging effect on many taxpayers including individuals, businesses, estates and trusts and this book will help taxpayers and tax advisors understand and prepare for the consequences of this new tax. Effective January 1, 2013 the new 3.8% Medicare tax is imposed on the lesser of "net investment income" or the excess (if any) of "modified adjusted gross income" over the "threshold amount."

• How does the surtax work
• What is "investment income"
• What is modified adjustment gross income
• What are the best strategies to reduce MAGI
• What are the best strategies to reduce investment income
• How life insurance will play an expanded role in income tax planning
• Will tax-exempt bonds continue to make sense
• How will tax deferred annuities work under the surtax
• Why Roth conversion will be a powerful strategy and more

Chapter 1. Overview—Unearned Income Medicare Contribution Tax (UIMCT)
Chapter 2. Application of the UIMCT to Individuals
Chapter 3. Application of the UIMCT to Trusts and Estates
Chapter 4. 2012 UIMCT Planning for Individuals and Businesses
Chapter 5. UIMCT Planning for 2013 and Later Years

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Published: September 2011

Written from a litigator’s perspective,The Deposition Handbook, 5th Edition delivers insights into how to make sure the witness becomes a champion for your side of the case. Find out how to effectively prepare the witness to testify most effectively and what factors to consider in deciding whether to prepare the witness to do more than just answer the question.

Gain valuable insights and skills, including:

• Practical advice covering every stage of a deposition
• Techniques for eliciting information and effective questioning
• Video deposition guidelines
• Proven strategies, procedures, and case studies
• Rules governing conduct
• Sample questions

Specific examples and scenarios cover:

• Whether counsel may interview an adverse party’s current or former employees
• Private conferences between the deponent and counsel during the course of the deposition
• The pros and cons of “the usual stipulations”
• Questioning techniques, including jumping from the specific to the general, and posing the either-answer question

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