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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Can Canadian taxpayers defer a gain on a disposition of property by reinvesting the sale proceeds like US taxpayers can?
The recent case of Livingston v The Queen from the Tax Court of Canada has once again thrust the replacement property rules in section 44 of the Income Tax Act (the “Act”) in the spotlight. Since numerous commentators have already discussed the case and debated whether the Tax Court was correct in its narrow interpretation of the legislation, we will take another approach and use this as an opportunity to highlight a common misconception about the Canadian replacement property rules that we frequently encounter in our practice.
The OECD’s Base Erosion and Profit Shifting (“BEPS”) Project
For tax geeks like me, the OECD’s BEPS project has been fascinating to watch and participate in the debate. On February 12, 2015, I attended 2015 BEPS Symposium – A Canadian Perspective, jointly presented by the Canadian Tax Foundation and International Fiscal Association Canada. The session was very interesting, exceptionally well presented, and a reminder that it is a great time to be a tax advisor despite (or because of) the crush of new developments.
Moodys Tax Law responds to Accounting Standards Board on proposed accounting treatment of redeemable preferred shares issued in tax planning arrangements
Our firm has long believed that accountants and lawyers should work together in the delivery of tax services. Both professions bring different skill sets and perspectives to the table when crafting client solutions. To that end, we purposely employ both professions in our tax law firm. It is common when dealing with tax matters that an issue will arise that requires input from both accountants and lawyers, and the subject of this article is a great example. In October 2014, the Accounting Standards Board (“AcSB”) released an Exposure Draft that, if implemented, will have great consequences for many private enterprises when reporting certain common tax planning arrangements.
CRA / IRS are coming to town!
You better watch out
You better not cry
You better not pout I’m telling you why
CRA / IRS are coming to town!
They’re making a list
And checking it twice
Gonna find out who needs MGTL’s tax advice
CRA / IRS is coming to town!
Restrictive covenant rules – good news update!
On July 28, 2014, our firm published a blog that discussed a recent Canada Revenue Agency (“CRA”) announcement at the 2014 Society of Trust and Estate Practitioners (“STEP”) Roundtable . The announcement involved the taxation of restrictive covenants under subsection 56.4(2) of the Income Tax Act (the “Act”). Specifically, the issue revolved around whether or not certain exceptions to the broad application of the taxation of restrictive covenant receipts could be avoided because of the strict application of the legislative requirement that no proceeds are received or receivable by the vendor for the granting of the restrictive covenant” (see paragraphs 56.4(6)(e) and 56.4(7)(d) of the Act).
Independent contractors – read this before incorporating
In Greek mythology, Icarus flew with wings made of feather and wax but he was overly-ambitious. Ignoring his father’s warnings, Icarus flew too close to the sun and the sun melted his wings causing him to fall into the water where he then drowned. Structuring oneself to provide services as an independent contractor comes with many advantages, and incorporating that business may bring additional advantages. However, in some circumstances, incorporating a ‘one-person’ business may be the same as flying too close to the sun.
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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