Alexander Marino recently appeared on the Global Investment Voice Podcast to discuss the benefits of renouncing US citizenship on March 14, 2024.
Alexander Marino guested on the Snowbirds US Expats Radio Podcast about the benefits of renouncing your US citizenship on January 17, 2024.
Kenneth Keung and Evan Crocker are quoted in Investment Executive article titled “CRAʼs 10% interest rate on overdue tax raises risks“, published on November 13, 2023.
Kenneth Keung quoted in Investment Executive article titled “Window closing on family business transfers using Bill C-208”, published on October 10, 2023.
Kim G C Moody is quoted in the Tax Notes article titled “Canada’s Supreme Court Upholds GAAR Application in Deans Knight”, May 30, 2023
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Meeting your US filing obligations in 6 steps:
Are you a US citizen living abroad? Did you know that the US taxes on both citizenship and residency? If you’re a US citizen, you are required to file yearly tax returns with the IRS – even if you don’t live on US soil.
Understanding and complying to US tax law requirements can be daunting. Here’s a useful infographic that will point you in the right direction.
More proposed reforms to small business taxation announced
The federal government continues to implement its agenda in respect of tax changes for small and medium sized private businesses, announcing further measures to increase taxation of this vital sector of the Canadian economy. These proposals come on the heels of other measures, for example the limitations to the small business deduction, which have already increased tax complexity and compliance costs for many small business owners. These new proposals are clearly an attack on entrepreneurs. Not good.
The impact of high personal and corporate tax rates
Recently, I had the honour and pleasure of speaking at one of Canada’s premier tax and estate planning conferences. While listening to some of the sessions, a number of speakers commented on Canada’s high tax rates as well as Alberta’s tax rate increases and compared such resulting top rate (48% on ordinary income) to Ontario’s rate (almost 54% on ordinary income). It was clear from the various updates that there was little sympathy for Albertans who gripe about the large rate increases in such a short period of time given the fact that there are other provinces with higher rates. This theme irritated me for reasons I will explain.
Could the Canada Revenue Agency ruin your next trip to Vegas?
The Canada Revenue Agency (CRA) has implemented a new policy where “accused” tax evaders are subject to fingerprinting. Although the CRA has fingerprinted some accused tax evaders in the past, this new policy appears to make the practice mandatory. CRA agents will no longer be able to exercise discretion on when to fingerprint persons. The policy requires that fingerprints be submitted to the Canadian Police Information Centre (CPIC).
Canada Revenue Agency expands relief for Canadian taxpayers with US LLLPs and LLPs
During the Canada Revenue Agency (CRA) roundtable at the International Fiscal Association (IFA) conference in Toronto earlier this week, the CRA announced “administrative grandfathering” for some Canadian taxpayers with investments in US Limited Liability Limited Partnerships (LLLPs) and US Limited Liability Partnerships (LLPs). Practically, this announcement will allow some Canadians who hold investments in US LLLPs and LLPs formed prior to April 26, 2017, to continue to treat these entities as partnerships on a go-forward basis. The CRA indicates that this additional relief resulted from the submissions which have been received by the CRA and the apparent complexities of transitioning from a partnership to a corporation.
The effective repeal of the flow-through share regime for the oil and gas industry in Western Canada
“We will fulfill our G20 commitment and phase out subsidies for the fossil fuel industry over the medium-term.” – Liberal Party of Canada Platform
You can’t say Justin Trudeau didn’t warn us. He made it very clear during his campaign to become Prime Minister that he planned to introduce legislation that would be damaging to the Western Canadian oil and gas industry.
The flow-through share regime has been a crucial element in the capital markets of Western Canada for oil and gas exploration and production companies (E&P companies). By issuing flow-through shares, and transferring corporate tax benefits of drilling from the corporation to the subscribing shareholders, E&P companies have, firstly, been able to issue shares in this highly risky business to arm’s length investors and, secondly, been able to reduce their cost of capital.
Alexander Marino recently appeared on the Global Investment Voice Podcast to discuss the benefits of renouncing US citizenship on March 14, 2024.
Alexander Marino guested on the Snowbirds US Expats Radio Podcast about the benefits of renouncing your US citizenship on January 17, 2024.
Kenneth Keung and Evan Crocker are quoted in Investment Executive article titled “CRAʼs 10% interest rate on overdue tax raises risks“, published on November 13, 2023.
Kenneth Keung quoted in Investment Executive article titled “Window closing on family business transfers using Bill C-208”, published on October 10, 2023.
Kim G C Moody is quoted in the Tax Notes article titled “Canada’s Supreme Court Upholds GAAR Application in Deans Knight”, May 30, 2023
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