Alexander Marino recently appeared on the Global Investment Voice Podcast to discuss the benefits of renouncing US citizenship on March 14, 2024.
Alexander Marino guested on the Snowbirds US Expats Radio Podcast about the benefits of renouncing your US citizenship on January 17, 2024.
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.
Kenneth Keung quoted in Investment Executive article titled “Window closing on family business transfers using Bill C-208”, published on October 10, 2023.
Kim G C Moody is quoted in the Tax Notes article titled “Canada’s Supreme Court Upholds GAAR Application in Deans Knight”, May 30, 2023
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Canada’s new Registration of Tax Preparers Program
On January 17, 2014, the Canada Revenue Agency (“CRA”) finally announced its intention to introduce a registration system for tax preparers who prepare tax returns for a fee. The new registration system, entitled Registration of Tax Preparers Program (“RTPP”), if implemented, will require tax preparers to register with the CRA during its 2016-2017 fiscal year.
Tax predictions for 2014 according to “Carnac the Magnificent”
Toward the end of the year, tax practitioners tend to flood the blogosphere with “last minute tax tips”. We prefer to take a different approach because good tax planning shouldn’t be “last minute”… it should be done year round. Furthermore, those able to anticipate tax changes are favourably positioned to plan their affairs accordingly, and in a proactive manner. Before Jay Leno introduced his “Headlines” comedy bit and before David Letterman introduced the “Top Ten List”, Johnny Carson appeared on stage in an outrageous costume and used his mystical powers of premonition as Carnac the Magnificent. In an ode to the King of Late Night, and with apologies to Ed McMahon, we give you “Carnac the Magnificent” and an assembly of the following tax predictions for 2014.
‘Twas The Night Before Christmas (Moodys Tax Law Version)
‘Twas the night before Christmas, with tax plans a ‘rouse;
Not a CRA auditor was stirring, they were all at their house.
The calculations were being made, with a jig and a prayer;
In hopes that the tax liability would soon disappear.
Supreme Court of Canada upholds rectification in Quebec tax cases
The Supreme Court of Canada (the “SCC”) recently released its decision in Quebec v. Services Environnementaux AES inc., 2013 SCC 65, which considered two cases where the Quebec Court of Appeal had allowed rectification as a remedy for taxpayers whose advisors had made an error in executing tax planning documentation. The SCC allowed rectification in both cases.
Designating excessive capital dividends as eligible dividends
Canada’s Income Tax Act (the “Act”) strives to achieve equality and neutrality in the taxation of income earned:
1. individually;
2. by a corporation that is taxed at the higher general corporate rate and then distributed to its individual shareholders; and
3. by a corporation that is taxed at the lower rate affected by the small business deduction and then distributed to its individual shareholders.
The general rate income pool (“GRIP”) and the low rate income pool (“LRIP”) as set out in section 89 of the Act is used to achieve this integration.
Morality and Tax
“…there is nothing sinister in so arranging one’s affairs as to keep taxes as low as possible. Everybody does so, rich or poor; and all do right, for nobody owes any public duty to pay more than the law demands…To demand more of mortals is mere cant.”
Learned Hand in Commissioner v. Newman, 159 F2d 848 (1947).
Everywhere you look lately, the press seems to be reporting another group or person that is pontificating about the “evils” of tax avoidance and tax planning. The usual rhetoric is that corporations or individuals who plan to reduce their taxes are engaging in immoral practices since they should be paying their “fair share”.
Alexander Marino recently appeared on the Global Investment Voice Podcast to discuss the benefits of renouncing US citizenship on March 14, 2024.
Alexander Marino guested on the Snowbirds US Expats Radio Podcast about the benefits of renouncing your US citizenship on January 17, 2024.
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.
Kenneth Keung quoted in Investment Executive article titled “Window closing on family business transfers using Bill C-208”, published on October 10, 2023.
Kim G C Moody is quoted in the Tax Notes article titled “Canada’s Supreme Court Upholds GAAR Application in Deans Knight”, May 30, 2023
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