Alexander Marino is quoted in an article titled “Trump bump: U.S. citizenship renunciation inquiries surge in Canada, lawyers say” on CBC News, January 28, 2025.
Alexander Marino is quoted in an article titled “‘Scary’: Why US expats are tossing their citizenships – and it’s not just Trump” in The Sydney Morning Herald, November 1, 2024
Kenneth Keung is quoted in the Investment Executive article titled “Quirk in capital gains tax rules raises risks for incorporated clients,” published on July 24, 2024.
Kenneth Keung is quoted in the Investment Executive article titled “How should trusts flow out capital gains to beneficiaries in 2024?”, July 5, 2024.
Kim G C Moody, Kenneth Keung, and Christopher Ellett are quoted in the Investment Executive article titled “When is the latest clients can sell assets prior to June 25?”, published on May 17, 2024.
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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.
A rare example of a one-client business found by the Tax Court to not be a personal services business
On August 12, 2015, the Tax Court of Canada (“TCC”) released its judgment in C.J. McCarty Inc. v The Queen1. McCarty is one of many personal services business (“PSB”) reassessment cases published in the recent years, but what makes this case interesting is that it is one of few where the taxpayer emerges successful despite having only one significant client and being compensated at a fixed hourly rate. In this short article, we will examine the unique facts that led the court to its judgment.
Planning using principal residence trusts for immigrants to Canada
As many of our readers know, the Canadian Income Tax Act (the “Act”) provides for an unlimited exemption from the imposition of Canadian income tax on the gains resulting from a disposition of a “principal residence”. Access to the principal residence exemption can be valuable, especially in cities (e.g. Vancouver, Toronto, Calgary) where residential properties have enjoyed robust appreciation.
Alexander Marino is quoted in an article titled “Trump bump: U.S. citizenship renunciation inquiries surge in Canada, lawyers say” on CBC News, January 28, 2025.
Alexander Marino is quoted in an article titled “‘Scary’: Why US expats are tossing their citizenships – and it’s not just Trump” in The Sydney Morning Herald, November 1, 2024
Kenneth Keung is quoted in the Investment Executive article titled “Quirk in capital gains tax rules raises risks for incorporated clients,” published on July 24, 2024.
Kenneth Keung is quoted in the Investment Executive article titled “How should trusts flow out capital gains to beneficiaries in 2024?”, July 5, 2024.
Kim G C Moody, Kenneth Keung, and Christopher Ellett are quoted in the Investment Executive article titled “When is the latest clients can sell assets prior to June 25?”, published on May 17, 2024.
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