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Member Articles


Do You Have a “GILTI” Tax for 2018, and What Are You Doing About It?

Author: Fuad S. Saba Congress introduced the GILTI tax with the TCJA at the end of 2017.  The tax applies to tax years beginning after December 31, 2017. GILTI is defined as the income of a “Controlled Foreign Co ...

Tax Me If You Can: Remaining in Compliance with the Canadian Cross-Border Tax

Author: Jeffrey Brown In the shadow of the recent Wayfair decision, more and more Canadian remote sellers now have to deal with state and local sales tax collection responsibilities. All too many are still thinking ...

Central Management and Control of Foreign Corporates in Australia

Author: Kurt Baker The Australian Taxation Office (“ATO”) recently issued final ruling TR 2018/5 setting out the Commissioners position on how to apply the central management and control tests when determining the t ...

Proposed Division 7A Amendments in Australia

Author: David Prichard The long-awaited Division 7A amendments have been released as a consultation paper with submissions closing on 21 November 2018. The proposals in the consultation paper do not exclusively follow t ...

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