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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Good news update from the Department of Finance regarding subsection 104(13.4)
On November 4, 2015, I wrote a short blog on the status of the discussions that the CBA/CPA Canada Joint Committee on Taxation, STEP, and CALU (the “Working Group”) have had with the Department of Finance regarding significant issues of concern raised by many tax, trust, and estate practitioners regarding subsection 104(13.4) of the Income Tax Act.
Today, I’m pleased to share with you a letter that the Department of Finance just released. In short, it states the Department of Finance has heard our concerns and is prepared to continue further discussions relating to specific recommendations made by the Working Group to amend subsection 104(13.4) to deal with the misplaced tax liability and charitable donation mismatch concerns.
Update on new Canadian trust taxation legislation – subsection 104(13.4)
Almost a year ago, I wrote about a piece of draft legislation – subsection 104(13.4) – that was introduced as part of the proposals to eliminate graduated rate taxation for Canadian resident testamentary trusts. I explained how troublesome subsection 104(13.4) will be when planning the affairs of Canadians who want to utilize “life interest trusts” such as alter ego, joint spousal/common law partner, or spousal trusts. Subsection 104(13.4) has since become law and will become effective January 1, 2016.
Tax rates, politics, and why you can’t hate your brother-in-law
Regardless of your political affiliation or philosophy on tax policy, change is coming. While we don’t have to welcome the change with loving arms, we do have to figure out how to productively work with it. We cannot, however, take up arms, become entrenched in our positions, and curse the new reality.
Tax and AC/DC
Those of you who know me well will know that my first career choice was to be a music teacher. I studied and played music classically well into my teens. When I realized that my talents would likely not provide me a stable living, I switched gears and became a Chartered Accountant. I still love music – all types of music with a few exceptions – but I have a soft spot for classic rock which is often playing in my office. One of my all time favorite bands is AC/DC. Their straight-ahead blues rock with very simple (almost comical) lyrics is exactly what I like to listen to when I need to turn my brain off (which doesn’t happen very often). Accordingly, I couldn’t pass up the opportunity to attend AC/DC’s concert in Edmonton on September 20, 2015.
Beware of wolves in the Canada Revenue Agency’s clothing
Telephone calls by fraudsters posing as Canada Revenue Agency (“CRA”) representatives who threaten immediate legal action unless a purported tax debt is paid continues despite warnings published by the CRA, media, and others. The fraudsters are often reported to have South Asian accents and to use aggressive and threatening language unless the fictitious tax debt is paid immediately (often by wire transfer or pre-paid credit card).
Donation of private corporation shares and real estate – new Canadian legislative proposals released
A number of years ago, the government introduced legislation (under paragraph 38(a.1) of the Income Tax Act – the “Act”) that exempts from taxation realized capital gains when publicly traded securities are gifted directly to registered charities. Subsequent to the introduction of such rules, many commentators have suggested that donations to charities from proceeds realized upon the disposition of real estate and private corporation shares should also be subject to a similar capital gains exception. The government has resisted introducing such measures until the 2015 Federal Budget (the “Budget”) which was released on April 21, 2015.
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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