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IRS releases Revenue Procedure 2010-19 relating to Canadian emigrants
  • Alston & Bird LLP
  • Canada, USA
  • April 15 2010

The IRS issued guidance for individuals who emigrate from Canada and who wish to make an election under the U.S.-Canada income tax treaty regarding Canadian departure tax (Revenue Procedure 2010-19

CNSX receives offshore securities market status from SEC
  • Stikeman Elliott LLP
  • Canada, USA
  • March 9 2010

The Canadian National Stock Exchange (CNSX) announced yesterday that the U.S. Securities and Exchange Commission (SEC) has designated it a "Designated offshore securities market" under Regulation S of the Securities Act of 1933

United States estate tax in 2010
  • Miller Thomson LLP
  • Canada, USA
  • May 14 2010

Federal estate tax in the United States is in a state of flux

U.S. FATCA creates potential compliance issues for Canadian financial institutions
  • Stikeman Elliott LLP
  • Canada, USA
  • August 2 2011

Our insurance group colleague Stuart Carruthers recently authored an article regarding the potential compliance issues emanating from certain provisions of the U.S. Hiring Incentives to Restore Employment Act known as the Foreign Account Tax Compliance Act

BLG Monthly Update
  • Borden Ladner Gervais LLP
  • Argentina, Australia, Canada, United Kingdom, USA
  • December 19 2012

The BLG Monthly Update is a digest of recent developments in the law which Neil Guthrie, our National Director of Research, thinks you will find

United States extends estate tax
  • Miller Thomson LLP
  • Canada, USA
  • May 1 2011

In the weeks and months leading up to December 2010, there was great uncertainty in the United States regarding the fate of the politically divisive 'estate tax.'

New disclosure requirements and added relief for U.S. taxpayers with undisclosed foreign assets
  • Gowling Lafleur Henderson LLP
  • Canada, USA
  • March 9 2012

The U.S. government has recently embarked on an aggressive campaign to reduce international tax evasion by U.S. citizens or permanent residents with undisclosed income and assets located in foreign countries

US estate tax on vacation homes
  • Miller Thomson LLP
  • Canada, USA
  • October 10 2012

In recent years, the high Canadian dollar and the fall in United States housing prices has encouraged Canadians to buy US vacation properties

Moving to the United States: tax consequences and planning opportunities
  • Gowling Lafleur Henderson LLP
  • Canada, USA
  • June 15 2008

Moving to the United States may raise all sorts of concerns for individuals resident in Canada, not the least of which are the potential tax consequences to such a move

New protocol to the Canada-US Tax Treaty: taxpayer emigration
  • McMillan LLP
  • Canada, USA
  • October 26 2007

One of the notable features of the Fifth Protocol (the “Protocol”) to the Canada-US Income Tax Convention (the “Treaty”) are the new provisions that are designed to prevent the double taxation of pre-emigration gains on property held by an emigrant