When it is intended that continued ownership would be held within a family, it is extremely important to consider the effect of the attribution rules when planning for the sale of stock to a ...

Permanent establishment (PE) refers to the deeming fiction created by domestic tax statues and/or double taxation avoidance agreements (DTAAs), which enables a country to tax the income attributable ...

There will be no taxable dividend, then, if a corporation redeems all of its stock owned by an estate. In determining what stock is owned by an estate, the constructive ownership or ...

In September 2018, as Hurricane Florence was heading towards a landfall in North Carolina, a team of researchers announced that the storm would be 80 kilometers larger and drop 50% more rainfall due ...

One of the most common questions I get from business owners is how they can set up their own individual 401(k) plan, without offering plan benefits to their employees. On its face, this question seems ...

It is no secret that Canada’s tax system encourages clients to attempt to shift investment assets to lower-income family members. The potential benefits of doing this have increased over the past ...