The fourth edition of this highly successful book explores the "inbound" international tax issues of non-residents of Canada who derive income from Canadian sources. Tax issues are analyzed in terms of the application of the relevant sections of the Income Tax Act and provincial statutes, the application of the Canada–U.S. Income Tax Convention, and the application of Canada's other tax treaties.

This edition has been updated with new case law and recent changes to legislation and CRA pronouncements for practitioners who deal with the subject matter and need to stay current on the issues to properly advise their clients.

Other significant updates include:

• Changes to the definition of "taxable Canadian property" and the resulting implications for non-residents who invest in Canadian property or realize capital gains from Canadian sources
• Expanded discussion on the changes that resulted from the Fifth Protocol to Canada-U.S. Treaty and CRA interpretations and statements since the last edition, including, particularly, expanded discussion of implications for hybrid entities such as LLCs and ULCs

Discussions and commentary on the above developments would be of interest to Canadian accounting and legal practitioners alike who act for individual or corporate non-resident clients. Corporations with U.S. employees working on short-term assignments in Canada would also be interested in this area of taxation. Also, non-resident professional advisors, particularly in the U.S., who need a general reference guide to assess the Canadian tax implications of certain past or proposed transactions, would find the content useful.

About the Author

Michael I. Atlas, C.A., C.P.A., T.E.P. is an accomplished author and long standing contributor to CCH. He is a Chartered Accountant who practices in Toronto as an independent tax consultant, in connection with a wide-range of domestic and international tax issues. Prior to forming his own practice in 1991, he was the partner in charge of the tax group of one of the 20 largest accounting firms in Canada. His consulting practice places particular emphasis on international and cross-border tax planning matters.

He has also been a frequent speaker on tax matters for many professional and business organizations, including the Canadian Tax Foundation, the Society of Trust and Estate Practitioners, the Institute of Chartered Accountants of Ontario, the Canadian Bar Association, and the Canadian Real Estate Association. Most recently, Michael has made a presentation entitled "Tax Issues for Non-Resident Investors in Canadian Real Estate" as part of "Creative Tax Planning For Real Estat

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Available: April 2012

Comprehensively analyzes all the tax laws applicable to individual retirement accounts. The first part of the book discusses the 15 different types of IRAs, including the four most recent types authorized by the tax laws: the Roth IRA, the education IRA, the SIMPLE IRA, and the deemed IRA. The second part discusses the various areas of tax law relating to the operation and administration of an IRA. There is a separate chapter on each area of the tax law. The third part of the book deals with taxation of distributions from an IRA, including premature distributions, minimum distributions during lifetime and after death, withholding taxes, and estate taxes. It also deals with the tax rules applicable to the different types of the beneficiaries receiving distributions from an IRA, including foreign beneficiaries, charitable beneficiaries, trust beneficiaries, estate beneficiaries, spouse and nonspouse beneficiaries, and individual and non-individual beneficiaries.

Related books:

• Federal Estate & Gift Taxes: Code & Regulations (Including Related Income Tax Provisions), As of 03/2012
• Estate Planning (2013 Edition) (U.S.) 
• U.S. Master Estate and Gift Tax Guide (2013) 
• Estate and Retirement Planning Answer Book, 2012 Ed. U.S.

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

Available: August 2011

Professors Richard C. Pugh, Charles H. Gustafson, and Robert J. Peroni

Compiled by a team of distinguished law professors, the 2011-2012 edition of INTERNATIONAL INCOME TAXATION: Code and Regulations-Selected Sections serves both students and practitioners in accessing the laws and regulations for U.S. international tax. For students, the INTERNATIONAL INCOME TAXATION: Code and Regulations-Selected Sections is a popular companion to an international tax course book for use in undergraduate or graduate courses in law and business schools. For practitioners, the book is an exclusive convenient desk reference. Unlike the full multi-volume Internal Revenue Code and Income Tax Regulations, this single-volume reference travels well between home and office.

Includes CD of entire contents of book.

In this comprehensive and easy-to-use volume, the authors have selected provisions of the Internal Revenue Code and Income Tax Regulations directly related to the U.S. taxation of foreign entities and the U.S. taxation of domestic entities that have income from sources outside the country.

The 2011-2012 edition of INTERNATIONAL INCOME TAXATION: Code and Regulations-Selected Sections reflects all legislation and regulations enacted or adopted on or before June 1, 2011.

• 1040 Express Answers (2012)
• 1041 Express Answers (2012)
• 1065 Express Answers (2012)
• U.S. Master Tax Guide®,2012
• ProSystem fx Tax: for U.S. Tax Returns
• INTERNAL REVENUE CODE: Income, Estate, Gift, Employment and Excise Taxes, Winter 2012 Edition
• U.S. INCOME TAX REGULATIONS, Winter 2012 Edition

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

Available June 2012

Part of the new CCH Beacon Series, Taxation of the Entertainment Industry 2012 is an insightful treatise that helps practitioners in entertainment tax planning:
• spot unique issues before they become problems,
• interpret rules and regulations correctly,
• make business decisions that lower taxes,
• and ensure compliance with the law.

This valuable reference by expert practitioner and author, Schuyler Moore, provides in-depth treatment of the taxation of film and television industries, including music and sports. It provides insights on proven strategies and techniques for achieving solid bottom-line results for those practitioners with clients within the entertainment industry.

Taxation of the Entertainment Industry sets forth details of an eight-point master plan for managing entertainment tax issues:
• Know how the law characterizes ownership rights and interests
• Choose a business form that provides maximum tax advantage
• Determine the best time to report and recognize income
• Reduce the tax burden through deductions, depreciation, and the investment tax credit
• Avoid liability for failure to withhold wages
• Realize tax deferral and tax savings through foreign production or distribution
• Discover innovative and creative strategies for financing film production and distribution, and 
• Pay close attention to the special tax considerations that apply to talent.

Moore thoroughly explains all of these issues, opportunities and challenges with clarity in this sure and steady guide through the ins and outs of entertainment tax law.

CONTENTS:
• Overview
• Fundamental Characterization Issues
• Choice of Entity
• Income Recognition, Timing and Characterization
• Deductions and Depreciation
• Wage Withholding
• Foreign Production and Distribution
• U.S. Tax Withholding on Foreign Persons
• Financing Using Domestic Tax Shelters
• Other Financing Methods
• Tax Planning for Talent
• California Taxation
• The Sports Industry
• The Music Industry
• Film Financing
• Forms

ABOUT THE AUTHOR:
Schuyler M. Moore is a partner in the Corporate Entertainment Department at the Los Angeles office of the national law firm of Stroock & Stroock & Lavan LLP.  He was the founding Chairman of the Entertainment Tax Subsection of the Los Angeles County Bar Association Taxation Section.  Mr. Moore holds undergraduate and law degrees from the University of California at Los Angeles, where he was first in his law class.  He has published numerous articles dealing with a wide variety of tax subjects and is the author of The Biz: The Basic Business, Legal and Financial Aspects of the Film Industry.  Mr. Moore is an adjunct professor for the UC

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The taxation of natural resources is one of the more complicated areas of the U.S. federal income tax system. From the acquisition of the mineral rights, to the exploration and development of the property, to the ultimate production of the mineral, there are unusual and challenging tax aspects along every step of the way.

Oil and Gas: Federal Income Taxation (2011) is an invaluable single-source handbook for accounting, tax and legal practitioners concerned with financial issues related to oil and gas industry tax law.  

Updated and revised by noted oil and gas taxation authority and educator, Patrick A. Hennessee, Ph.D., CPA , this detailed reference is divided into six main sections:

• Introduction to Oil and Gas Taxation
• Acquisition of Interests
• The Exploration Period
• The Production Period
• Dispositions
• Other Areas

The text begins with a discussion of the nature of oil and gas reserves in order to gain a better understanding of the industry. The material following is organized in a logical sequence of events which traces the normal industry pattern for developing oil and gas reserves.

Special features include:

• A special ''Highlights of New Developments'' section provides a convenient, at-a-glance summary of recent tax legislation, case law, rulings, position papers, etc., as they relate to the oil and gas industry, and it tells readers where in the volume they can find additional information on the specific topics.
• Reflects all the recent developments in place, including new legislation, regulations and case law changes impacting this area since the previous edition published, allowing tax and legal professionals to stay current on this highly specialized area of tax law.  
• Enables understanding of the myriad technical aspects of oil and gas taxation by thoroughly discussing the critical issues of:
  • economic interests
  • lease and purchase arrangements
  • royalties
  • working or operating mineral interest
  • production payments
  • net profits arrangements
  • geological and geophysical expenses
  • intangible drilling and development costs
  • sharing arrangements and carried interests
  • depletion
  • gross income from property
  • taxable income from property
  • unitizations
  • disposition of interests
  • nontaxable exchanges
  • losses and abandonments
  • types of ownership
  • alternative minimum tax
  • nonconventional fuel credit
  • depreciation
  • a

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

    
    
    Full Article
    
    

• Oil and Gas Tax Reporter Tax Trends Newsletter (monthly) - tracks federal energy legislation, IRS rulings, federal cases, state tax, and other developments.
• Multistate Oil and Gas Severance Tax Interactive Chart – allows you to quickly find the applicable oil or gas severance tax rates for any state jurisdiction, with citations to the state laws.
• Oil and Gas Tax Reporter – edited by industry experts, providing many illustrative examples and tax planning considerations for oil and gas ventures, citations to controlling authorities, and updated quarterly to reflect the latest developments. Covers the tax provisions unique to the oil and gas industry, from exploration, through development, the production phase, and sales and other dispositions of the properties. Includes coverage of issues unique to oil and gas companies in various areas, including tax credits, depreciation, and accounting methods.
• Internal Revenue Manual - Oil and Gas Handbook – IRS internal guidelines for the examination of income tax returns of taxpayers involved in the oil and gas industry.
• ISPs/MSSPs – IRS papers establishing examination uniformity within industry categories; the publication includes the IRS Audit Technique Guide for the Oil & Gas Industry.

Contact your CCH account manager today or contact Benoit Filion.

Content is divided into six main sections, organized to trace the industry pattern for developing oil and gas reserves – updated at least quarterly (more often as needed)

The content is easy to follow for practitioners familiar with the industry, as the presentation of the material mirrors the professional’s normal course or workflow, with an overview for each topic.

1.    Introduction to Oil and Gas Taxation             Chapter 1
2.    Acquisition of Interests                                    Chapters 2 -- 8
3.    The Exploration Period                                    Chapters 9 -- 10
4.    The Production Period                                     Chapters 11 -- 18
5.    Dispositions                                                      Chapters 19 -- 21
6.    Other Areas (losses and aba

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

Full Article

Available: Late June 2012

Provides step-by-step guidance on the taxation of fiduciary income. This comprehensive guide for practitioners advising fiduciaries and beneficiaries in federal income tax matters covers the broad range of complex issues from charitable remainder trusts to nexus rules and their effect. Providing expert practical advice, this book helps the practitioner obtain the most advantageous outcomes for his/her fiduciary and beneficiary clients. Key feature: 35 case studies with filled-in forms 1041 and accompanying documents.

Volume 1:

1. Overview of the Fiduciary Entity
2. The Fiduciary (Trust) Accounting Concept; Total Return Investment Philosophy
3. Principles of Federal Income Tax for Fiduciaries
4. Itemized Deductions
5. Distributions
6. Capital Gains and Alternative Minimum Taxes, Accounting Periods and Special Rules
7. Estimated Taxes
8. Passive Activity Loss Limitations
9. Trusts: Formation to Termination
10. Charitable Remainder Trusts
11. Charitable Lead Trusts
12. Alternative Use of Grantor Trusts in Transactional Planning
13. Ownership of S Corporation Stock by Trusts--Emphasizing Qualified Subchapter S Trusts and the New More Flexible Electing Small Business Trust
14. Grantor Trust Rules
15. Foreign Trusts Treated as Grantor Trusts

Volume 2:

1.  Estates: Formation to Termination
2. Income Tax Aspects of Fiduciary Ownership and Administration of Family Limited Partnership (FLP) Interests
3. Income Tax Aspects of Generation-Skipping Transfers
4. State Taxation of Fiduciaries and Beneficiaries
5. Special Commercial Trusts
6. IRS Ruling Policy and Audits; Responsibility for Filing and Payment of Tax
7. Foreign Trusts and Estates

Related books:

• U.S. Master Estate and Gift Tax Guide (2013) 
• Family Foundation Handbook (2013) – U.S.
• Estate and Retirement Planning Answer Book, 2012 Ed. U.S.

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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.

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

Understanding the Taxation of Partnerships is now available online. Use your online subscription to: 

• Search research content instantly
• Access your applicable CCH subscriptions; all integrated
• Save research to your electronic client files
• Enjoy access virtually anywhere

Understanding the Taxation of Partnerships is the only publication in Canada that provides a comprehensive analysis of tax issues affecting one of the most common forms of business organization. This publication provides in-depth analysis of the tax issues that must be considered when a partnership is used as a business or investment vehicle.

The sixth edition of this indispensable reference is a complete guide to understanding Canadian income tax rules including important developments in case law and administrative practice affecting partnerships. This edition has been updated to include:

• changes to the Canada–US treaty that have affected the use of partnerships in cross-border planning;
• the SIFT partnership rules;
• recent cases that have implications for partnerships; and
• additional material on partnerships in the foreign affiliate context.

Other topics covered include:

• how partnerships differ from joint ventures and other entities;
• computation of partnership income;
• the "at-risk" rules;
• transfers of property to and from partnerships, and other reorganizations involving partnerships;
• professional partnerships; and
• partnerships in the international context.

The 6th Edition is current to September 30, 2010.

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

Introduction to Federal Income Taxation in Canada, 32nd Edition gives you a smart learning advantage – here’s how:

• Each chapter includes examples, problems, multiple choice questions, and exercises designed to reinforce the material and text comprehension – with solutions provided for the student
• Review questions throughout the textbook include discussion notes at the end of the book
• Assignment problems and advisory cases have solutions provided in the Instructor’s Solutions Manual
• Student DVD includes extra problems and solutions for self-study
• CCH research software and CANTAX software also included on DVD

New this year – Student Study Guide:  This guide contains the solutions to the Review Question, Multiple Choice Questions, and Exercises, as well as additional study material and a glossary.

Income Tax Act compliant

Students dedicated to taxation and students interested in developing a solid general understanding of federal tax law will benefit from this resource. The contents are arranged in a sequence that follows the organization of the Income Tax Act for easy cross-referencing.

Reality checked

We know accuracy is critical and we pride ourselves on providing the most accurate and current content.

• Updated annually to reflect Budget and other legislative changes to income tax provisions
• All assignment materials have been carefully prepared and tested

Robert E. Beam, F.C.A., is a Professor Emeritus in the School of Accounting and Finance, University of Waterloo. He was associated with Ernst & Young, Chartered Accountants, Toronto.

From 1972 to 1998, he was Coordinator of the Tax Section of the School of Accountancy, Institute of Chartered Accountants of Ontario. In September 2002, Mr. Beam became the first recipient of the Canadian Institute of Chartered Accountants Award for Excellence in Tax Practice and Education. His articles have appeared in the Canadian Tax Journal.

Stanley N. Laiken, Ph.D., is the Deloitte Professor in the School of Accounting and Finance, University of Waterloo. He has taught taxation to students in professional programs, both at the university and post-university levels, since 1972.

He is a recipient of the Distinguished Teacher Award at the University of Waterloo and the Canadian Academic Accounting Association’s L.S. Rosen Award in recognition of outstanding contributions to Canadian accounting education. His articles have appeared in the Canadian Tax Journal. He is also the Director of the Deloitte Centre for Tax Education and Research at the University of Waterloo.

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

Compiled by a team of distinguished law professors, the 2010-2011 edition of INTERNATIONAL INCOME TAXATION: Code and Regulations--Selected Sections serves both students and practitioners in accessing the laws and regulations for  U.S. international tax. For students, the INTERNATIONAL INCOME TAXATION: Code and Regulations--Selected Sections is a popular companion to an international tax coursebook for use in undergraduate or graduate courses in law and business schools. For practitioners, the book is an exclusive convenient desk reference.  Unlike the full multi-volume Internal Revenue Code and Income Tax Regulations, this single-volume reference travels well between home and office -- and between classroom and dorm. The book features a reader-friendly large 7-1/4" x 10" format with new larger type fonts for enhanced readability.

Includes CD of entire contents of book.

In this comprehensive and easy-to-use volume, Professors Richard C. Pugh, Charles H. Gustafson, and Robert J. Peroni have selected provisions of the Internal Revenue Code and Income Tax Regulations directly related to the U.S. taxation of foreign entities and the U.S. taxation of domestic entities that have income from sources outside the country.  Code and Regulations sections included are those deemed to be essential to International Tax teachers, students and practitioners.

The 2010-2011 edition of INTERNATIONAL INCOME TAXATION: Code and Regulations--Selected Sections reflects all legislation and regulations enacted or adopted on or before June 1, 2010.

You may also be interested in:
INTERNAL REVENUE CODE: Income, Estate, Gift, Employment and Excise Taxes, (Summer 2010 Edition)

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

Available: November 2011

This book is an invaluable single-source handbook for accounting, tax and legal practitioners concerned with financial issues related to oil and gas industry tax law.

Updated and revised by noted oil and gas taxation authority and educator, Patrick A. Hennessee, Ph.D., CPA , this detailed reference is divided into six main sections: 

• Introduction to Oil and Gas Taxation
• Acquisition of Interests
• The Exploration Period
• The Production Period
• Dispositions
• Other Areas

The text begins with a discussion of the nature of oil and gas reserves in order to gain a better understanding of the industry. The material following is organized in a logical sequence of events which traces the normal industry pattern for developing oil and gas reserves.

• Special features include: A special "Highlights of New Developments" section provides a convenient, at-a-glance summary of recent tax legislation, case law, rulings, position papers, etc., as they relate to the oil and gas industry.
• Reflects all the recent developments in place, including new legislation, regulations and case law changes impacting this area since the previous edition published.
• Enables understanding of the myriad technical aspects of oil and gas taxation by thoroughly discussing the critical issues of:

1. Introduction to Oil and Gas Taxation
2. Economic Interest
3. Lease and Purchase Arrangements
4. Royalty and Overriding Royalty
5. Minimum Royalties
6. Working Interest (or for Operating Mineral Interest)
7. Production Payments
8. Net Profits Arrangements
9. Geophysical Expenses
10. Intangible Drilling and Development Costs
11. Sharing Arrangements and Carried Interests
12. Depletion Deduction – General
13. Allowance or Disallowance of Depletion
14. Property for Depletion Purposes
15. Cost Depletion
16. Gross Income from the Property
17. Taxable Income from the Property for Depletion Purposes
18. Limitations on Percentage Depletion
19. Unitizations
20. Disposition of Interests – Lease (or Sublease) and Sale
21. Nontaxable Exchanges
22. Losses and Abandonments
23. Associations Taxable as Corporations
24. Partnerships
25. Selected Corporate Issues
26. Alternative Minimum Tax (AMT)
27. Special Provisions Affecting the Determination of Tax
28. Tax Credits
29. Depreciation
30. Application of Accounting Methods
31. Oil and Gas International Provisions
Case Table
Finding Lists   

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

The comprehensive expert commentary of Value-Added Taxation in Canada: GST, HST, and QST, 4th Edition is now available online. Use your subscription to:

• Search research content instantly
• Access your applicable CCH subscriptions; all integrated
• Save research to your electronic client files
• Enjoy access virtually anywhere

Value-Added Taxation in Canada is an in-depth analysis of the Goods and Services Tax, its harmonized counterpart currently applicable in Nova Scotia, New Brunswick, Newfoundland and Labrador, Ontario, and British Columbia, and the Quebec Sales Tax. The book combines both practical and theoretical issues, with emphasis on practical applications for private and public sector taxpayers. The authors have integrated the impact of the three taxes (GST, HST, and QST) on each topical area. These taxes are extensively referenced throughout the book, providing insight into the legislation and administrative policy at both the federal and provincial levels. In addition, the format is designed to accommodate the further harmonization of other jurisdictions in Canada.

This edition has been updated to reflect the legislation, regulations, government policies, and proposed amendments up to January 1, 2011.

Table of Contents (Condensed)

CHAPTER 1 – INTRODUCTION
CHAPTER 2 – REGISTRATION
CHAPTER 3 – SUPPLY
CHAPTER 4 – PLACE OF SUPPLY
CHAPTER 5 – VALUE OF CONSIDERATION
CHAPTER 6 – WHEN TAX IS PAYABLE
CHAPTER 7 – IMPORTS AND INTERPROVINCIAL TRANSFERS
CHAPTER 8 – EXEMPT SUPPLIES
CHAPTER 9 – ZERO-RATED SUPPLIES
CHAPTER 10 – INPUT TAX CREDITS AND INPUT TAX REFUNDS
CHAPTER 11 – REBATES
CHAPTER 12 – ORGANIZATIONAL CONSIDERATIONS
CHAPTER 13 – FINANCIAL INSTITUTIONS
CHAPTER 14 – INDUSTRY-SPECIFIC ISSUES
CHAPTER 15 – COLLECTION AND REMITTANCE OF TAX
CHAPTER 16 – ADMINISTRATION AND ENFORCEMENT

About the Author:

Ryan is a leading global tax services firm, with the largest indirect tax practice in North America and the seventh largest corporate tax practice in the United States. Since 1974, the Firm’s Canadian practice, located in Mississauga, Ontario, has performed work for more than 6,500 organizations on a variety of tax matters, both provincially and nationally. Headquartered in Dallas, Texas, Ryan provides a comprehensive range of state, local, federal, and international tax advisory and consulting services on a multi-jurisdictional basis, including audit defence, tax recovery, credits and incentives, tax process improvement and automation, tax appeals, tax compliance and strategic planning.

In 2010, If you would like more details about this product, or would like to order a copy online, please click here.

Author: Schuyler M. Moore

Taxation of the Entertainment Industry is an insightful treatise that helps practitioners in entertainment tax planning spot unique issues before they become problems, interpret rules and regulations correctly, make business decisions that lower taxes, and ensure compliance with the law. This valuable reference by expert practitioner and author, Schuyler Moore, provides in-depth treatment of the taxation of film and television industries, including music and sports. It provides insights on proven strategies and techniques for achieving solid bottom-line results for those practitioners with clients within the entertainment industry.

Taxation of the Entertainment Industry sets forth details of an eight-point master plan for managing entertainment tax issues:

• Know how the law characterizes ownership rights and interests
• Choose a business form that provides maximum tax advantage
• Determine the best time to report and recognize income
• Reduce the tax burden through deductions, depreciation, and the investment tax credit
• Avoid liability for failure to withhold wages
• Realize tax deferral and tax savings through foreign production or distribution
• Discover innovative and creative strategies for financing film production and distribution, and  
• Pay close attention to the special tax considerations that apply to talent.

• Overview
• Fundamental Characterization Issues
• Choice of Entity
• Income Recognition, Timing and Characterization
• Deductions and Depreciation
• Wage Withholding
• Foreign Production and Distribution
• U.S. Tax Withholding on Foreign Persons
• Financing Using Domestic Tax Shelters
• Other Financing Methods
• Tax Planning for Talent
• California Taxation
• The Sports Industry
• The Music Industry
• Film Financing
• Forms