My first e-publication!!

Yahoo!

My book "Who gets my tax dollars?" has just been published as an e-publicaiton on Smashwords.com for 5.99.  See my book page to the left or jump straight to my book page.

Entertainers and Sportsmen - OECD changes

They used to be called Athletes and Artistes (and still are in several treaties). The OECD now refers to them as entertainers and sportsmen. The OECD recently released a discussion draft to propose some changes to their commentary.

The change that most twigged my interest is the fact that a one-time amateur sports winner of a race could now be considered in this category. So, if the running race has a cash prize - it could be subject to tax withholding.

LLCs and Canada/US Treaty

In an interesting decision the TCC decided that "properly interpreted and applied in context in a manner to achieve its intended object and purpose, the US Treaty’s favourable tax rate reductions apply for years prior to the Fifth Protocol Amendments to the Canadian‑sourced income of a US LLC if all of that income is fully and comprehensively taxed by the US to the members of the LLC resident in the US on the same basis as had the income been earned directly by those members".

The treaty was changed because both governments fully believed that it didn't apply to LLCs - now, the courts apparently aren't as sure.