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Sunita Doobay
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US Partnership Interest Sale Triggers 10 Percent Withholding
Recently published in  Canadian Tax Highlights  - a Canadian Tax Foundation newsletter and republished here with permission: The 600-plus-page GOP tax bill was signed by President Trump on December 22, 2017, becoming Public Law no. 115-97, commonly known as...
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Dual Resident Estate
Recently published in Canadian Tax Highlights - a Canadian Tax Foundation newsletter and republished here with permission:   For Canadian purposes, an estate is now deemed to be a trust
under a 2013 amendment to the subsection 248(1) definition of a trust. ...
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Tax Proposals - US and Canada
President Trump released his tax proposals today while in Canada the Morneau proposals consultation period will be ending soon on October 2nd, 2017. The Morneau proposals have caused many of us tax practitioners sleepless nights given how far reaching the p...
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Tax Implications of Cryptocurrency
Virtual currency or cryptocurrency has become
popular in today’s financial markets and may be here for some time. Investors
increasingly turn to virtual currency to fund transactions and provide
portfolio diversity. The rising popularity of virtual currency...
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Two‐Year Holding of CCPC Options
Montminy ( 2016 TCC 110 ) is the first case to consider the interaction between regulations 6204(1)(b) and 6204(2) (c). The TCC concluded that the latter does not apply to negate the two-year reasonable holding period in the former. Were the taxpayers in Mo...
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US Country‐by‐Country Reporting
The US Treasury and the IRS implemented country-by-country (CbC) reporting requirements to ensure that US multinational enterprises (MNEs) are not subject to CbC filing obligations in multiple foreign tax jurisdictions. US CbC reporting requires the ultimat...
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The Common Reporting Standards
With over 100 countries as signatories to the CRS Multilateral Competent Authority
Agreement there will be little need
for incidents such as the Panama papers ( https://panamapapers.icij.org/ ) for
tax authorities to find out what their tax residents were s...
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Shielding Non-Resident's Assets via a Canadian LP
Before December 12, 2016, a common tactic for non-Americans was to shield their assets through a Delaware LLC. On the formation of an LLC in Delaware, the beneficial ownership was not disclosed. Thus, a German individual could hold his Parisian condo in an ...
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Ontario (not Alberta) Resident Trust
Ontario (not Alberta) Resident Trust
Ontario (not Alberta) Resident Trust
taxruminations.blogspot.com
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Tax Under Appeal not Debt in Bankruptcy
Tax Under Appeal not Debt in Bankruptcy
Tax Under Appeal not Debt in Bankruptcy
taxruminations.blogspot.ca
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