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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The 2014 Federal Budget – The top five tax matters to watch for
On January 27, 2014, the Department of Finance of the Government of Canada announced that the 2014 Federal Budget would be released on February 11, 2014. Budgets of late have typically been released in March. No doubt, the Department must have been very busy getting ready for February 11. While the rest of Canada will be cheering for our athletes in the Sochi Olympics, tax geeks like us will be “cheering” or “booing” at the release of the Budget.
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.
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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