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What's the difference between Canadian tax law and American tax law?

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CanuckLawyer

Junior Member
What is the name of your state? Canada.

In all common law jurisdictions, the general principles are the same for almost all areas of law. So the law of contract in some American states and most Canadian provinces talk of offer acceptance, unconscionability, and duress. And family law in these places also talk of the best interests of the child, seperation, custody and access.

But tax law may not be the same, because there are no general principles in tax law. And yet, at the same time, the same problems must arise between the two countries, which are of course very similar. So I'm asking - is there a big difference between American tax law and Canadian tax law, or can one expert transfer his expertise between countries?
 


LdiJ

Senior Member
What is the name of your state? Canada.

In all common law jurisdictions, the general principles are the same for almost all areas of law. So the law of contract in some American states and most Canadian provinces talk of offer acceptance, unconscionability, and duress. And family law in these places also talk of the best interests of the child, seperation, custody and access.

But tax law may not be the same, because there are no general principles in tax law. And yet, at the same time, the same problems must arise between the two countries, which are of course very similar. So I'm asking - is there a big difference between American tax law and Canadian tax law, or can one expert transfer his expertise between countries?
I doubt that anyone here can answer that question with any certainty, however I can tell you that I know for certain that at least some areas of Canadian tax law are VERY different than US tax law. However, I don't know that because my US expertise translates, but rather because I have family in Canada and have observed some of the differences.

If you wanted to prepare US tax returns for Canadian residents you could certainly take the time to study the instructions and do them properly, particularly if you were willing to find US associates to consult with if you were stymied by something....and the reverse could probably also apply.

However, if you are expecting that being an expert in one country makes you an expert in the other....no way.

If you are a taxpayer looking for assistance, its quite possible that you could find a firm that has experts on staff in both Canadian and US tax law.
 

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