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?”
Alexander Marino appeared on the Jim Richards Show on Newstalk 1010 in Toronto on September 4, 2025 to discuss “Why are some Americans renouncing their US citizenship?”
Kim G C Moody has authored the article, “The tax hit to Canadians from Trump’s ‘big beautiful’ bill could be tremendous” in The Financial Post, May 27, 2025.
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The Alberta Election, overtime playoffs, and a night full of upsets…
Growing up in Alberta, my parents taught me a golden rule – never talk about politics in a social setting. A golden rule I still respect and one that has carried over to our firm. However, I’m going to make an exception today (sorry Mom) given the historic nature of yesterday’s Alberta election.
Upcoming FATCA deadlines for Canadians
As part of its 2015 Federal Budget announcements, Canada committed to implementing the “Common Reporting Standard” (CRS) promulgated by the Organization for Economic Co-operation and Development (OECD). While the OECD’s efforts to facilitate information reporting via the CRS and Canada’s corresponding implementation of such a regime will certainly have lasting impact, let us not forget about the progenitor of information exchange and its looming deadlines: FATCA.
2015 Federal Budget summary
Well, as predicted, the 2015 Federal Budget (the “Budget”) contained significant tax measures. After years and years of boring tax budgets, recent budgets have reversed that trend and the 2015 Budget is certainly no exception. For those of you who do not have the patience, nor energy, to read this entire summary, below is a recap of the more relevant tax measures that will impact our clients and friends.
2015 Federal Budget predictions
By now, most of us know that the ruling Conservatives announced they will release the Federal Budget (calling it Economic Action Plan 2015 – the “Budget”) on April 21, 2015. Once again, I will be in attendance in Ottawa representing CPA Canada and our firm. What do I predict will be contained in the Budget? Well, it’s anyone’s guess. My favorite management writer, Peter Drucker, once wrote: “Trying to predict the future is like trying to drive down a country road at night with no lights while looking out the back window.” In addition, the ancient Chinese philosopher, Lao Tzu, stated: “Those who have knowledge, don’t predict. Those who predict, don’t have knowledge.” Well, I think Peter Drucker and Lao Tzu were both right. But, I’m willing to take a shot at what we might see in the Budget. Here’s my best guess.
Government of Alberta announces a newsworthy budget for 2015
Budget announcements from the Government of Alberta for the last number of years have generally been humdrum events. Unfortunately, with declining oil prices and market uncertainty, the Government of Alberta is now in a position where it can no longer rely on resource royalties to smooth out its revenue stream. Through Budget 2015, the Government of Alberta is proposing changes that will impact many Albertans in a significant way.
The loss restriction event rules for trusts are broader than you think
Loss carryforwards and other tax attributes are valuable assets because they can shelter taxes. As such, loss utilization has always been a staple of good tax planning. The Income Tax Act and the CRA’s administrative policies have generally accepted loss utilization planning within affiliated and related parties. On the other hand, the Act has always had provisions against arm’s length loss trading transactions whereby one taxpayer in effect makes use of another’s unused tax attributes. Prior to March 21, 2013, these rules were referred to as the “acquisition of control” rules and they applied only to corporations. However, in recent years, there are a proliferation of non-corporate vehicles that carry on substantial activities traditionally undertaken only by corporations. In response, the Department of Finance introduced a new “loss restriction event” concept in new section 251.2, effective March 21, 2013, that essentially expands the old acquisition of control regime to partnerships and trusts. At first glance, the rules in section 251.2 appears to be of limited relevance to ordinary trust and estate planning due to the affiliated person exceptions provided. However, there are traps for the unwary contained in these rules.
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?”
Alexander Marino appeared on the Jim Richards Show on Newstalk 1010 in Toronto on September 4, 2025 to discuss “Why are some Americans renouncing their US citizenship?”
Kim G C Moody has authored the article, “The tax hit to Canadians from Trump’s ‘big beautiful’ bill could be tremendous” in The Financial Post, May 27, 2025.
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