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

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

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

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Kenneth Keung and Evan Crocker are quoted in Investment Executive article titled “CRAʼs 10% interest rate on overdue tax raises risks“, published on November 13, 2023.

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Kenneth Keung quoted in Investment Executive article titled “Window closing on family business transfers using Bill C-208”, published on October 10, 2023.

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Are you walking into a tax disaster – Incorporated contractors & taxes (part I)

The Tax Court of Canada (“TCC”) decision in G&J Muirhead Holdings Ltd. v Queen, released on February 13th, 2014, dealt with whether a one-person service company was carrying on a personal services business (“PSB”). Although the decision did not represent any shift in judicial thinking on the subject, it is nonetheless useful in clarifying the role of subjective intention in PSB determination and serves as a stern reminder for incorporated contractors to structure their engagements with eyes wide open.

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T1135 Transitional guidance

Late today, the Canada Revenue Agency (“CRA”) provided transitional reporting guidance in respect of prescribed Form T1135 for taxpayers who own specified foreign property with a cost of $100,000 or more. There were two transitional provisions provided but such relief is only applicable for 2013.

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Olympic Tax?

We here at Moodys Tax are caught up in the Olympic fever (Go Canada Go!)…but like always…

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“Black is the new grey” – Treaty interpretation in the Conrad Black appeal

Winston Churchill said there is “no such thing as a good tax” and thus it surely follows that no good can come from double taxation. While it’s difficult to feel sympathy for Lord Black who earned approximately $3.39 million with another $1.7 million of taxable benefits in 2002, the underlying principles are important to all who rely on the relief provided in tax treaties to avoid double taxation.

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Clampdown on improper joint venture GST/HST S.273 election but regime to be expanded

On February 6, 2014, the CRA issued its final warning, in the form of GST/HST Notice No. 284, to joint ventures that use bare trust nominees to file GST/HST returns on their behalf. The CRA has always maintained that such practice is inconsistent with section 273 of the Excise Tax Act (the “ETA”) and it announced that it will no longer tolerate the practice after 2014. Interestingly, as part of the 2014 federal Budget released less than a week afterwards, the Department of Finance proposed to expand the section 273 election regime so that more commercial joint ventures can benefit from the regime.

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The 2014 Federal Budget – Our tax “free” comments

Today, Finance Minister James Flaherty delivered his 10th Federal Budget (the “Budget”). Surprisingly, the Budget contained a lot more tax content than expected. For those who do not have the energy to plow through the details or the Budget documents, here is a quick summary.

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***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.

***CLICK FOR ALL NEWS***

Kenneth Keung and Evan Crocker are quoted in Investment Executive article titled “CRAʼs 10% interest rate on overdue tax raises risks“, published on November 13, 2023.

***CLICK FOR ALL NEWS***

Kenneth Keung quoted in Investment Executive article titled “Window closing on family business transfers using Bill C-208”, published on October 10, 2023.