Practice Makes Perfect: IRS Releases New International Practice Units

By Robert Robillard - 23 March 2016

This blogpost originally appeared on rbrt.ca. The IRS has been busy releasing 10 new practice units: 03-18-2016 Inbound Resale Price Method Routine Distributor 03-18-2016 Computing Foreign Base Company Income for US Individual Shareholders 03-17-2016 Concepts of Foreign Personal Holding Company...

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Canada-United Kingdom Tax Convention: Arbitration Provisions Coming Soon

By Robert Robillard - 1 December 2015

This blogpost originally appeared on rbrt.ca. Department of Finance recently indicated: "An Agreement concerning the application of the arbitration provisions of the Convention between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern...

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OECD: Model Tax Convention on Income and on Capital 2014 (Full Version)

By Robert Robillard - 4 November 2015

This blogpost originally appeared on rbrt.ca. The OECD indicates: "This publication is the ninth edition of the full version of the OECD Model Tax Convention on Income and on Capital. This full version contains the full text of the Model...

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ICC’s Statement on Misuse of Customs Valuation Databases: Foreshadowing the Future Use of CbC Reporting Data?

By Robert Robillard - 2 November 2015

This blogpost originally appeared on rbrt.ca. People worrying about the upcoming use, misuse (and likely abuse) of CbC reporting data by tax authorities may be interested by this one... The International Chamber of Commerce recently stated: "The International Chamber of Commerce...

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Canada: Uncertain Tax Position Analysis not Safe from the CRA [2015 FC 714]

By Robert Robillard - 8 September 2015

This blogpost originally appeared on rbrt.ca. Canada (National Revenue) v. BP Canada Energy Company 2015 FC 714 provides an interesting glimpse into the upcoming tax audit world. Contrary to popular beliefs, this decision does not indicate that working papers should nowadays be...

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Constructive Presence: US Resident – Proposed Amendments to Section 937 IRC

By Robert Robillard - 2 September 2015

This blogpost originally appeared on rbrt.ca. New REG-109813-11 [Residence Rules Involving U.S. Possessions] proposes "amendments to the regulations for determining whether an individual is a bona fide resident of a U.S. territory. These proposed amendments affect individuals establishing bona fide...

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