Alexander Marino was a guest on the “This is Ottawa” CBC podcast episode titled ‘I feel alienated from my U.S. identity’ on March 23, 2026.
Alexander Marino was interviewed for the CBC news story “Dual citizens weigh Trump, taxes in decision to renounce US citizenship” on March 23, 2026.
Kim GC Moody was a guest on The Current with Matt Galloway on CBC Radio, on September 22, 2025 discussing “Why can’t you get a CRA agent on the line?”
Alexander Marino appeared on CONNECT With Sarah Crosbie on Corus Radio on September 16, 2025, to discuss “Are YOU an Accidental American?”
Alexander Marino appeared on The Ben Mulroney Show on Corus Radio on September 16, 2025, to discuss “Have You Heard About Accidental Americans?”
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2016 Canadian federal budget predictions
In what’s becoming our firm’s annual tradition, the purpose of this blog is to gaze into the crystal ball to predict what the tax goodies might look like when the 2016 federal budget is released. The timing of such a release is anyone’s guess, but some prognosticators are suggesting the third week of March 2016. We certainly can’t add any credibility to that guess since the timing of the budget release is usually a carefully guarded secret – and rightly so.
With the above in mind, here are our predictions and a bit of a wish list.
New legislative proposals for trusts – dealing with the subsection 104(13.4) problem
On Nov. 16, 2015, I wrote about the ongoing saga regarding subsection 104(13.4) and some good news that was released by the Department of Finance. Today, the Department of Finance released legislative proposals as a follow-up and are seeking comments on such proposals no later than Feb. 15, 2016. While we are still absorbing some of the material, here are the very quick observations.
Half a loaf is better than none!
The Federal Court of Appeal’s (FCA) recent French language decision in the appeal of Gervais considered the use of a sale structure commonly referred to as the “half loaf.” In general, this planning technique provides an opportunity to spouses to increase the use of the capital gains deduction (CGD) in cases where only one spouse owns property (and a disposition of which would give rise to an opportunity for use of the CGD). The Tax Court decision in Gervais of Jorre J. was largely based on the finding that a transfer of capital property from one spouse to another, that was immediately resold to an unrelated party, was on account of income and not capital.
Beginning January 1, 2016: File your US tax return or risk losing your US passport
US citizens living outside the United States will need to become even more vigilant about filing US taxes and having a US Social Security number starting Jan. 1, 2016. The alternative will be to risk losing one’s passport under a new section of the Internal Revenue Code.
Canada Revenue Agency releases new Form T1135 to report foreign property
On Dec. 9, 2015, the Canada Revenue Agency (CRA) released a new version of prescribed Form T1135 for taxpayers who own specified foreign property (SFP). The new form allows taxpayers who own SFP that have a total cost between $100,000 and $250,000 a more simplified reporting option.
Federal tax rate increases for Canadians
On December 7, 2015, Canada’s new Finance Minister, Bill Morneau, tabled measures to reduce the federal individual income tax rate for the $45,282 to $90,563 tax bracket from 22% to 20.5%, and introduced a new 33% top rate bracket for taxable income over $200,000, effective Jan. 1, 2016. Additionally, the Tax-Free Savings Account (TFSA) annual contribution limit will be rolled back to $5,500 after 2015. While these amendments were not unexpected as they were part of the Liberal’s election platform, the proposal also includes subtle but important consequential amendments affecting tax rates/credits for trusts and estates, “kiddie tax”, charitable donations, corporate refundable taxes on investment income for Canadian-controlled private corporations (CCPCs), and Part IV tax. This short blog summarizes these changes and offers some thoughts.
Alexander Marino was a guest on the “This is Ottawa” CBC podcast episode titled ‘I feel alienated from my U.S. identity’ on March 23, 2026.
Alexander Marino was interviewed for the CBC news story “Dual citizens weigh Trump, taxes in decision to renounce US citizenship” on March 23, 2026.
Kim GC Moody was a guest on The Current with Matt Galloway on CBC Radio, on September 22, 2025 discussing “Why can’t you get a CRA agent on the line?”
Alexander Marino appeared on CONNECT With Sarah Crosbie on Corus Radio on September 16, 2025, to discuss “Are YOU an Accidental American?”
Alexander Marino appeared on The Ben Mulroney Show on Corus Radio on September 16, 2025, to discuss “Have You Heard About Accidental Americans?”
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