Kim GC Moody was a guest on The Current with Matt Galloway on CBC Radio, on September 22, 2025 discussing “Why can’t you get a CRA agent on the line?”
Alexander Marino appeared on CONNECT With Sarah Crosbie on Corus Radio on September 16, 2025, to discuss “Are YOU an Accidental American?”
Alexander Marino appeared on The Ben Mulroney Show on Corus Radio on September 16, 2025, to discuss “Have You Heard About Accidental Americans?”
Alexander Marino appeared on the Jim Richards Show on Newstalk 1010 in Toronto on September 4, 2025 to discuss “Why are some Americans renouncing their US citizenship?”
Kim G C Moody has authored the article, “The tax hit to Canadians from Trump’s ‘big beautiful’ bill could be tremendous” in The Financial Post, May 27, 2025.
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Staying onside – incorporated contractors & taxes (Part II)
In Are you walking into a tax disaster – Incorporated contractors & taxes, we discussed when an incorporated contractor could be considered to be carrying on a personal services business (“PSB”) and the adverse tax consequences that follow. Part II of this series explores strategies incorporated contractors may consider in order to stay onside within these rules.
We’re on a Mission!
Back in the day, a T2P (downtown) postal code was essential to our Calgary office’s well-being. But as we’ve grown, and our brand has matured, we’ve become comfortable setting trends and making Strategic changes. And making a change has never felt so right…
Dividend vs. bonus: How your remuneration strategy may affect interest deductibility
The Federal Court of Appeal (“FCA”) in Swirsky v. R., 2014 FCA 36 recently upheld the Tax Court of Canada (“TCC”)’s decision (2013 TCC 73) to disallow the deduction of interest pursuant to paragraph 20(1)(c) of the Income Tax Act (the “Act”) on money that was borrowed to buy shares of the family’s corporation. Two key factors led to the decision to disallow the interest expense. The first was the trial judge’s finding of fact that the borrower’s subjective intention when obtaining the loans was creditor-proofing. The second was the objective fact that the shares of the family’s corporation had no history at paying dividends; instead the corporation had in the past remunerated its owner-manager by paying a bonus to him and providing advances via his shareholder loan account.
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.
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.
Olympic Tax?
We here at Moodys Tax are caught up in the Olympic fever (Go Canada Go!)…but like always…
Kim GC Moody was a guest on The Current with Matt Galloway on CBC Radio, on September 22, 2025 discussing “Why can’t you get a CRA agent on the line?”
Alexander Marino appeared on CONNECT With Sarah Crosbie on Corus Radio on September 16, 2025, to discuss “Are YOU an Accidental American?”
Alexander Marino appeared on The Ben Mulroney Show on Corus Radio on September 16, 2025, to discuss “Have You Heard About Accidental Americans?”
Alexander Marino appeared on the Jim Richards Show on Newstalk 1010 in Toronto on September 4, 2025 to discuss “Why are some Americans renouncing their US citizenship?”
Kim G C Moody has authored the article, “The tax hit to Canadians from Trump’s ‘big beautiful’ bill could be tremendous” in The Financial Post, May 27, 2025.
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