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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“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.
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.
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.
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.
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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