Blog + News

Insight on what’s happening in the world of tax, law and accounting so you can stay ahead.

***CLICK FOR ALL NEWS***

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.

***CLICK FOR ALL NEWS***

Kenneth Keung is quoted in the Investment Executive article titled “How should trusts flow out capital gains to beneficiaries in 2024?”, July 5, 2024.

***CLICK FOR ALL NEWS***

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.

***CLICK FOR ALL NEWS***

Alexander Marino recently appeared on the Global Investment Voice Podcast to discuss the benefits of renouncing US citizenship on March 14, 2024.

***CLICK FOR ALL NEWS***

Alexander Marino guested on the Snowbirds US Expats Radio Podcast about the benefits of renouncing your US citizenship on January 17, 2024.

All
  • All
  • Accounting
  • Alexander Marino JD, LLM (US Tax)
  • Announcements
  • Business Law
  • Canadian Tax
  • Christmas
  • Federal Budget
  • Firm News
  • Flowcharts
  • Immigration & Travel
  • Living Abroad
  • Personal Notes
  • Publications
  • Team Profiles
  • Trust & Estate Law
  • US Citizenship Renunciation
  • US Tax
  • Webinar Recordings

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).

Read More

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.

Read More

Personal tax credits and all-inclusive resorts

So what does tax and all-inclusive resorts have in common? While away, it got me thinking how some of the recent personal tax credits announced by the Conservative Government resemble certain characteristics of an all-inclusive resort. All-inclusive resorts are a people-watching mecca but more famously are known for their numerous all you can eat buffets and unlimited alcohol (good, bad and ugly). To parallel the two, while there are certainly good sides to the recent amendments to the Children’s Fitness Tax Credit, the Universal Child Care Benefit (“UCCB”), Child Care Expense Deduction and the new “Family Tax Cut” credit, there are many distasteful aspects as well.

Read More

New draft legislation will have a great impact on traditional estate planning for Canadians

On August 29, 2014, the Department of Finance released 100+ pages of draft legislation. Much of the draft legislation was to enact the 2014 Federal Budget proposals. However, there were a couple of nasty surprises, one of which will have a great impact on traditional estate planning for Canadians. The Department of Finance gave interested parties until September 28, 2014 to provide comments.

Read More

Updated IRS streamlined filing program: snowbirds beware

On October 8, 2014, the IRS issued FAQs clarifying its amnesty programs for non-compliant taxpayers who want to catch-up on their U.S. tax filing obligations.1 These FAQs address the recently amended streamlined filing compliance procedures, offshore voluntary disclosure program (OVDP), and delinquent information return and FBAR submission procedures.2 The FAQs are not relatively enlightening, except for the FAQ on the nonresident streamlined procedures (dubbed the “Streamlined Foreign Offshore Procedures” by the IRS). After briefly summarizing some relevant general rules regarding streamlined, this blog will address the consequences of that FAQ for snowbirds who have not filed during the three-year period for which tax returns must be submitted under streamlined and, according to the IRS, spend too much time in the United States. Ultimately, these snowbirds are ineligible for streamlined and must find an alternative way to catch-up with their U.S. tax filing obligations.

Read More

Does the increased fee for renouncing US citizenship indicate a change in attitude toward expatriates?

Uncle Sam just managed to dig out a quarter hiding in his couch. Or maybe his patience…

Read More

***CLICK FOR ALL NEWS***

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.

***CLICK FOR ALL NEWS***

Kenneth Keung is quoted in the Investment Executive article titled “How should trusts flow out capital gains to beneficiaries in 2024?”, July 5, 2024.

***CLICK FOR ALL NEWS***

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.

***CLICK FOR ALL NEWS***

Alexander Marino recently appeared on the Global Investment Voice Podcast to discuss the benefits of renouncing US citizenship on March 14, 2024.

***CLICK FOR ALL NEWS***

Alexander Marino guested on the Snowbirds US Expats Radio Podcast about the benefits of renouncing your US citizenship on January 17, 2024.