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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Triple Canadian taxation possible with subsection 55(2)
The recent Tax Court of Canada’s decision in 101139810 Saskatchewan Ltd. v Queen (2017 TCC 3) did not cover any new ground with respect to subsection 55(2), but it was a useful reminder of the pitfalls one could encounter for running afoul of that provision. This short blog highlights what went wrong, and the court’s indifference to the taxpayer’s predicament.
Whip that WIP: Canada’s proposed tax repeal of a professional’s WIP exclusion election
Earlier this week, we provided our summary of the 2017 federal budget released on March 22, 2017. The Budget contained a little-publicized but important tax change for how Canadian professionals will report their taxable income going forward. Effective for taxation years beginning after March 21, 2017, every professional must include its year-end work-in-progress (WIP) in its taxable income. For professionals, WIP generally represents unbilled time and supplies incurred in the rendering of services to clients. This blog will attempt to explain the current rules governing the recording of WIP and the history behind these rules, illustrate the impact of the proposed measures, and the practical challenges professionals will face. We will also provide a few tax policy comments to close.
Renouncing US Citizenship Or Giving Up A Green Card: Why And How To Consider It
Israel and the United States share a strong bond, and U.S. citizenship or permanent resident status allows access to the largest economy in the world. Why would a dual Israeli-U.S. citizen, or an Israeli who has been granted a U.S. “green card,” ever consider giving that up? Increasingly, the answer is one word: tax.
Unique among global powers, the United States taxes the worldwide income of its citizens and permanent resident status holders no matter where they live. Additionally, the requirement that an Israeli-U.S. citizen or green card holder file an annual U.S. income tax return is not waived by the fact that the United States grants a credit for taxes paid to Israel. In fact, many U.S. citizens living abroad do not actually owe U.S. tax, but they can face very stiff monetary penalties for failing to file required disclosures about non-U.S. assets in a timely manner.
The 2017 federal budget: what’s changed, what hasn’t
On March 22, 2017, the federal Liberal government released their 2nd budget. This blog provides an executive summary, in-depth analysis, and commentary on the tax measures announced by the federal government that will impact taxpayers.
Renouncing your US citizenship: Failed amendment may signal that now is the time to get out!
If you are one of the many U.S. citizens contemplating renouncing your U.S. citizenship, Congress has sent fairly clear messages that now, as opposed to later, may be the right time to get out of the club. On June 12, 2013, U.S. Senators Jack Reed (D-RI) and Chuck Schumer (D-NY) attempted to add yet another hurdle to the ongoing saga for those individuals looking to renounce their U.S. citizenship when they filed an amendment to an immigration reform bill…
Challenges Canadians face when transferring US retirement plans to an RRSP
Canada and the US share many similarities including the longest international border between two countries. Due to the proximity of the two countries, many Canadians find themselves living and working in the US and contributing pre-tax dollars into employer-sponsored retirement plans such as the 401(k) and Individual Retirement Account or IRA (collectively, US-based retirement plans). Once their US employment ends, many Canadian workers returning to their home country must eventually undertake the task of determining what to do with their US-based retirement plans as retirement age draws near (the Canadian retirees).
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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