North America: Tax

The increased federal estate tax exemption under the One Big Beautiful Bill Act may have reduced the number of estates subject to federal estate tax, but for married New York residents, credit shelter trusts remain an important planning consideration.

When it comes to estate planning, even the rich and famous are not immune to costly mistakes. This examination of celebrity estate planning mishaps reveals how iconic figures have fallen victim to oversights leading to legal battles, unintended heirs, and millions in tax losses, offering valuable lessons for legal professionals and individuals alike.

Understanding the various types of trusts available in Canada is essential for effective estate planning and asset management. From family trusts and alter ego trusts to qualified disability trusts and bare trusts, each structure offers distinct advantages for tax planning, probate avoidance, and protecting beneficiaries with special needs. This comprehensive overview examines the key requirements, uses, and tax implications of common trust structures to help you determine which option best suits your estat

A corporation’s residence for tax purposes and the jurisdiction under which it is incorporated are legally distinct concepts. The corporate statute that governs a corporation, whether the Canada Business Corporations Act (“CBCA”) or a provincial equivalent, dictates its internal governance rules, but it does not, on its own, determine where the corporation is resident in Canada for the purposes of the Income Tax Act.

The U.S. Treasury and IRS have issued comprehensive regulations implementing the new Section 25F Education Freedom Tax Credit, creating federal incentives for individual taxpayers to contribute to Scholarship Granting Organizations that fund K-12 educational scholarships. With an estimated $26 billion in annual contributions expected by 2030, these regulations address critical operational questions including credit calculations...

STC Steel Technologies Canada, Ltd. v. The King, 2026 TCC 149 [STC Steel] addresses an important question for corporate groups that use different tax reporting currencies: when a Canadian subsidiary with accumulated Canadian-dollar non-capital losses is wound up into a parent corporation reporting in U.S. dollars, when are those losses converted, and which exchange rate applies?

Corporations are treated as distinct legal persons, separate from their shareholders, directors, and officers.

Canada has one of the largest tax treaty networks in the world. Its Canadian tax treaties are designed to prevent double taxation, allocate taxing rights between countries, and reduce Canadian non-resident withholding tax on cross-border dividends, interest, royalties, and similar payments.

Canada's tax system imposes income taxes at both federal and provincial/territorial levels on corporations and individuals, with rates varying significantly based on business structure, location, and other factors.

Can the CRA Deny a New Housing Rebate Even If You Actually Used the Property? Yes. A purchaser’s actual use of a newly acquired home does not, by itself, establish entitlement to the GST/HST New Housing Rebate.

A New York Court of Claims judge has ordered substantial revisions to how New York City administers its Pied-à-Terre tax surcharge, canceling previously issued notices and shifting the burden of proof to the Department of Finance. The ruling requires individualized determinations before notices can be sent and eliminates the controversial exemption application process that had confused thousands of property owners. While the decision doesn't strike down the PAT law itself, it fundamentally restructures

While those upward bracket shifts may provide meaningful tax savings on higher-value properties, Washington’s Real Estate Excise Tax (“REET”) structure remains one of the most closely watched elements of transactional planning for commercial and residential property owners and developers. Because Washington applies a tiered, progressive REET rate system for real estate sales, alongside strict rules governing the transfer of controlling interests in entities that own real property, even minor statutory adjustments can drastically alter the economics of a transaction if deal timing or contract mechanics are mishandled.