The Supreme Court of Canada has delivered judgments in two critical cases involving the General Anti-Avoidance Rule. These long-awaited decisions are the most important developments in tax law in the past decade. Are you on the right side of GAAR?

History
When GAAR was introduced in 1988, it gave Revenue Canada very broad powers to challenge perceived tax avoidance activity. And since its genesis, there have been many justifiable concerns regarding GAAR's impact on tax planning. The bottom line is that GAAR has the power to affect any transaction that has the purpose of eliminating or reducing tax. But there has been little in the way of practical guidance to make informed planning decisions – until now.

The Essential GAAR Manual: Policies, Principles and Procedures is written by Canada's most highly regarded team of experts on GAAR issues at Fraser Milner Casgrain LLP: William I. Innes, LLB, LLM; Patrick J. Boyle, LLB; and Joel Nitikman, LLB, LLM. It was designed with your tax planning practice in mind and includes useful and accessible reference tools that will arm you with the knowledge and insight to inform your clients properly. It answers questions that will affect your tax planning strategies, such as:

• What's the future of GAAR after Canada Trustco and Mathew?
• What's a "textual, contextual and purposive" analysis?
• What does the Supreme Court of Canada mean by requiring that tax measures be "predictable"?
• What is the future of corporate tax planning?
• What is the future of family and estate planning?
• How will commercial tax shelters fare under the "new" GAAR analysis?
• How does a practitioner cope with the post-Canada Trustco climate?
• How do you document a transaction that may be probed by GAAR?

The author team goes beyond a descriptive and substantive analysis and provides you with key insights into the practical application of GAAR considerations for your day-to-day practice. As the application evolves, the CRA is likely to invoke GAAR with more frequency.

Resources

• The Bottom Line Magazine: Canada's premier newspaper for accountants – The Essential GAAR Manual
• CCH Publishes First Comprehensive GAAR Manual (11/04/2006)

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

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.

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

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

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

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.

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

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

Related Products

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.

Byrle M. Abbin

This 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, Income Taxation of Fiduciaries and Beneficiaries 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

16. Estates: Formation to Termination
17. Income Tax Aspects of Fiduciary Ownership and Administration of Family Limited Partnership (FLP) Interests
18. Income Tax Aspects of Generation-Skipping Transfers
19. State Taxation of Fiduciaries and Beneficiaries
20. Special Commercial Trusts
21. IRS Ruling Policy and Audits; Responsibility for Filing and Payment of Tax
22. Foreign Trusts and Estates

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

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

16.    Estates: Formation to Termination

17.    Income Tax Aspects of Fiduciary Ownership and Administration of Family Limited Partnership (FLP) Interests

18.    Income Tax Aspects of Generation-Skipping Transfers

19.    State Taxation of Fiduciaries and Beneficiaries

20.    Special Commercial Trusts

21.    IRS Ruling Policy and Audits; Responsibility for Filing and Payment of Tax

22.    Foreign Trusts and Estates

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

This practical reference contains all of the important authoritative pronouncements on GAAP with references to ASC codification, and the corresponding references to the original literature, including APB Opinions, Accounting Research Bulletins, FASB Statements, Staff Positions, Interpretations, Technical Bulletins, and Concepts, as well as AICPA Statements of Position as an aid. Securities and Exchange Financial Reporting Releases and EITF Issues are also covered when appropriate.

This volume contains accounting principles, financial reporting presentation requirements, required and recommended disclosures, and specialized accounting topics. The book includes examples, tables, exhibits, and practice aids that demonstrate how to apply GAAP in practice. In some cases, flowcharts are presented to explain, in clearer terms, the practitioner's decision process in applying a pronouncement. Current footnotes from annual reports provide clear examples of reporting.

The book also comes with a free companion CD-ROM that contains an electronic version of the book.

The 2013 GAAP Handbook covers the following topics:

PART I:       FINANCIAL STATEMENTS
PART II:      MAJOR ACCOUNTING AREAS AND REPORTING
PART III:     FOREIGN OPERATIONS AND DERIVATIVE INSTRUMENTS
PART IV:     GAAP IN SPECIALIZED INDUSTRIES

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

The GAAP Handbook provides many rules of thumb. Its content includes informative rules, policies, and procedures applicable to CPAs and may be used as a training medium.
    
This practical reference contains all of the important authoritative pronouncements on GAAP with references to ASC codification, and the corresponding references to the original literature, including APB Opinions, Accounting Research Bulletins, FASB Statements, Staff Positions, Interpretations, Technical Bulletins, and Concepts, as well as AICPA Statements of Position as an aid. Securities and Exchange Financial Reporting Releases and EITF Issues are also covered when appropriate.
        
The book also comes with a free companion CD-ROM that contains an electronic version of the book.

PART I: FINANCIAL STATEMENTS

• Reporting, Presentation, and Disclosures for the Income Statement
• Revenue Recognition
• Balance Sheet Reporting and Disclosures: Assets
• Balance Sheet Presentation and Disclosures: Liabilities
• Balance Sheet Reporting: Stockholders' Equity
• Statement of Cash Flows
• Other Financial Statement Types and Related Items
• Disclosures

• Accounting Changes and Error Corrections
• Investments in Equity and Debt Securities
• Business Combinations
• Consolidation
• Leases
• Pension Plans and Other Postretirement Benefit Plans
• Income Tax Accounting

• Foreign Currency Translation and Transactions
• Derivatives, Repurchase Agreements, and Disclosures of Credit Risk and Fair Values: Accounting,  Reporting, and Disclosures
• International Financial Reporting Standards: An Examination of Accounting Convergence

• Accounting in Specialized Industries

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

Mark L. Ascher. J.D., LL.M.,

Brings you up to date on the latest developments in this complex and constantly changing area.

Only customers of the existing book, Federal Income Taxation of Estates, Trusts & Beneficiaries should order this product if they are not on a standing order basis to receive supplements.

1. The Income Tax Meaning of Estates and Trusts
2. Decedent's Income Tax Liability for the Year of Death
3. Income in Respect of Decedents
4. Partnership Interests
5. Distributable Net Income
6. The Charitable Deduction
7. Distributions
8. The Passive Activity Rules
9. The Throwback Rule
10. Grantor Trusts
11. Split-Interest Charitable Trusts
12. Termination and Modification
13. The Executor's Personal Liability for Federal Taxes of the Decedent and the Estate

Table of Cases
Table of Internal Revenue Code Sections
Table of Treasury Regulations
Table of Revenue Rulings
Table of Federal Statutes
Table of State Statutes
Table of Uniform and Model Acts
Table of Restatements of Law
Index

Related Products

Estate & Gift Tax Handbook (2014) (U.S.)
Estate & Retirement Planning Answer Book, 2015 Edition (U.S.)
Family Foundation Handbook (2014) (US)
Federal Estate & Gift Taxes: Code & Regulations (Including Related Income Tax Provisions), as of March 2014 (U.S.)
Federal Income Taxation of Decedents, Estates and Trusts - 2015 CCH Tax Spotlight Series (U.S.)
Income Taxation of Fiduciaries and Beneficiaries (2014) (U.S.)
Like-Kind Exchanges Under Code Section 1031 – CCH Tax Spotlight Series (U.S.)
Multistate Guide to Estate Planning (2015) (w/CD)
U.S. Master Estate and Gift Tax Guide (2015)
Business Succession Planning Answer Book – 2015 (U.S.)
Fiduciary Accounting Answer Book, 2015 (U.S.)
Grantor Trust Answer Book, 2015 (U.S.)
Practical Guide to Estate Planning, 201

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

Only customers of the existing book, Federal Income Taxation of Estates, Trusts & Beneficiaries should order this product if you are not on a standing order basis to receive supplements.

Provides step-by-step guidance for dealing with the problems of preparation of the decedent’s final return, characterization of income in respect of a decedent, computation of distributable net income (DNI), the interaction of the system of taxation of trusts and estates and the passive activity rules, the grantor trust rules, and the rules relating to split interest charitable trusts.

CONTENTS:
1.    The Income Tax Meaning of Estates and Trusts
2.    Decedent's Income Tax Liability for the Year of Death
3.    Income in Respect of Decedents
4.    Partnership Interests
5.    Distributable Net Income
6.    The Charitable Deduction
7.    Distributions
8.    The Passive Activity Rules
9.    The Throwback Rule
10.    Grantor Trusts
11.    Split-Interest Charitable Trusts
12.    Termination and Modification
13.    The Executor's Personal Liability for Federal Taxes of the Decedent and the Estate

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

Available: June 2012

Author: Mark L. Ascher

Only customers of the existing book, Federal Income Taxation of Estates, Trusts & Beneficiaries should order this product if you are not on a standing order basis to receive supplements.

Provides step-by-step guidance for dealing with the problems of preparation of the decedent’s final return, characterization of income in respect of a decedent, computation of distributable net income (DNI), the interaction of the system of taxation of trusts and estates and the passive activity rules, the grantor trust rules, and the rules relating to split interest charitable trusts.

CONTENTS:

1. The Income Tax Meaning of Estates and Trusts
2. Decedent's Income Tax Liability for the Year of Death
3. Income in Respect of Decedents
4. Partnership Interests
5. Distributable Net Income
6. The Charitable Deduction
7. Distributions
8. The Passive Activity Rules
9. The Throwback Rule
10. Grantor Trusts
11. Split-Interest Charitable Trusts
12. Termination and Modification
13. The Executor's Personal Liability for Federal Taxes of the Decedent and the Estate

Loose-leaf book

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.

Rotch Library - NA2599.5.F76 2019

Online Resource

Duffy, Joanne R., author

Turgeon, Mary Louise, author

Barr, Donald A., author

Nabarro, Laura, author

Wilkinson, Ian (Ian Boden), author