Case Study: Temporary Assignment Of An Employee From Canada To The United States

This article is the first in a series of four parts that will examine the Canadian and U.S. income tax implications when an employee employed by a Canadian entity is assigned temporarily to work in the U.S. This first article focuses on the importance of the determination of “residency” for personal income tax purposes. Future articles will address personal tax liabilities based on different residency determinations, the concept of tax equalization, corporate payroll matters, […]

By |March 11th, 2015|

United States: Let The Training Begin: MTC Transfer Pricing Audits Draw Near

Deputy Executive Director Greg Matson (a nice guy at heart) announced this week that the Multistate Tax Commission (MTC) has hired its first transfer pricing training consultant and is scheduled to begin training state auditors.  The training, titled “Identifying Related Party Issues in Corporate Tax Audits” will be hosted by the North Carolina Department of Revenue from March 31 to April 1, 2015 in Raleigh, North Carolina.  While the much anticipated Arm’s Length Adjustment […]

By |March 10th, 2015|

Cayman Islands: Miliband Is Hopelessly Out Of Touch On Tax Avoidance

Reprinted from the Financial Times Letters Section 10.2. 2015

Sir, with his comments on the role of the overseas territories, Labour leader Ed Miliband shows himself as more hopelessly out of touch in relation to international tax avoidance than in relation to domestic matters. In fact, the overseas territories have maintained complete records on ultimate beneficial ownership to the international gold standard set by the OECD for more than two decades.

Quite what the OECD would […]

By |March 10th, 2015|