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About

BoTax

Jeffrey Brown, former principal of BoTax, has joined Fuller Landau LLP effective January 10, 2018 to provide US federal and state tax advisory services to two distinct client groups.

The first group includes US citizens and persons who are resident in Canada but have US tax and information return filing obligations. Many times, these clients are either non-compliant with their US filing obligations or their filings are unknowingly defective. Our team, often working with US legal counsel, helps these clients “get in the system” or remediate defective filings. Normative actions can include (1) participation on the US Offshore Voluntary Disclosure Program #3, (2) streamlined filings, (3) “FAQ 18” filings or (4) preparation of amended returns. In all circumstances, we can work with a client’s incumbent US tax return preparer, if the client so chooses.

US persons in Canada often have unique estate and retirement planning challenges. Again, our team can work with US legal counsel, the client’s chartered accountant, and financial advisors to develop a competent estate tax plan.

The second group of clients includes Canadian businesses that have US federal and state tax filing obligations. We offer in-house expertise advising on state and local tax matters including income tax and sales and use tax.

Under the leadership of Jeffrey Brown, the US Tax Team at Fuller Landau has years of experience assisting clients with IRS and state tax controversies starting with routine replies to notices from the tax authorities to audit representation through the appeals process. We can also assist clients in securing federal and state tax rulings.

Jeffrey Brown

Jeffrey BrownJeffrey is a US certified public accountant fully licensed in Massachusetts and New York State. Jeffrey has been called to the bar in Massachusetts, Rhode Island, and the US Tax Court. Jeffrey has 30 years of public accounting experience and has been practicing in Canada since 2002. On January 10, 2018, Jeffrey joined the partnership group at Fuller Landau LLP, where he leads the firm’s thriving US Tax practice. Jeffrey is a frequent author and highly sought-after lecturer. His articles have appeared in the National Post, Globe & Mail, and numerous trade publications. Jeffrey has lectured for the Tax Executive Institute, the Council for International Tax Education, and the Institute of Chartered Accountants in Canada.

For more information on Jeffrey Brown and his role at Fuller Landau LLP, click here.

Services

Jeffrey Brown assists Canadian businesses and US expats in Canada, along with their tax and legal advisors, on matters pertaining to US federal and state taxation. Often, these services involve remedial efforts to resolve problems with past tax filings or lack thereof. Proactive engagement and planning is preferred and is often most effective.

Business tax services include assistance with US federal and state tax compliance such as the preparation of US tax returns, business registrations, and sales and use tax registration and filing. Our team works with legal counsel and Canadian tax advisors to set up the most tax effective US operating structures, from both Canadian and US perspectives. For the entrepreneur, this includes giving due consideration to Canadian tax devices that don’t exist in the United States such as the capital gains exclusion, as well as addressing devices in Canada that can be problematic such as no-par shares.

Ex-pat tax services include working with Canadian and US tax advisors on behalf of US persons in Canada. Many times, these files involve complexities that previously were not considered significant, but are today. Tax freeze structures, estate planning and gifting, and the reporting of Canadian tax devices that do not have a US counterpart such as RRSPs, RESPs and TFSAs present unique challenges for Americans in Canada.

We represent taxpayers before the Internal Revenue Service and state and local tax authorities, and will handle tax controversies through the appeals process. We will support legal counsel throughout the tax litigation process and can operate with US tax counsel when attorney-client privilege may be in order through a “Kovel agreement”.