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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The FBAR is NOT in the mail
US citizens who live abroad, including Canada, need to be aware of a quirk of this year’s calendar that accomplishes the impossible – adding pressure and confusion to the FBAR filing process. While US tax law is not known for its benevolence, it does at least offer the “mailbox rule”, which (generally) considers a document submitted on the date that it is postmarked (international filers should check with their advisors to determine how this applies in their specific locale). The FBAR, however, has its origins not in US tax law but rather in the Bank Secrecy Act and is not subject to the mailbox rule.
Underwater? CRA relief may be available
Southern Alberta was recently hit by the worst flooding the province has ever seen according to Premier Redford – but in true Alberta spirit, the Province is rallying together to recover from this natural disaster! With respect to tax obligations, it is important to note that if you or your business were unable to meet some of your tax obligations due to the recent flooding, relief from the Canada Revenue Agency (the “CRA”) may be available.
Proposed changes to the taxation of Canadian testamentary trusts
In the 2013 Federal Budget, the Department of Finance announced that the Canadian government would review how testamentary trusts are taxed and would release a consultation paper at a later date. On June 3, 2013 the consultation paper was released by the Department of Finance and can be viewed here. The Department of Finance is seeking input from interested parties no later than December 2, 2013. For practitioners who practice in this area, the short consultation paper will no doubt be mandatory reading since the proposed changes raised in the paper, if implemented, would be a landmark change for testamentary trusts.
Moodys Tax Advisors present at Canadian Tax Foundation Prairie Provinces Tax Conference
The Canadian Tax Foundation Prairie Provinces Tax Conference, held on May 27 & 28, took place in the same city where Moodys recently opened a new office – Edmonton, Alberta. Partners Kim G C Moody and Greg Gartner presented at the well attended conference on topics covering Owner Manager Remuneration and Provincial Residency, respectively.
Canadian Tax Court comments on cross-border financing structure
The Tax Court of Canada recently released their decision in Lehigh Cement Limited v. R. and CBR Alberta Limited v. R., 2013 TCC 176, which deals with whether a cross-border financing structure ran afoul of a specific anti-avoidance provision in the Income Tax Act (the “Act”). The Court closely examined the wording of the provision and held in favour of the Taxpayers (collectively, Lehigh Cement Limited and CBR Alberta Limited).
Dai-showa-me-the-money: The Supreme Court of Canada decision in Daishowa-Marubeni v. R.
Yesterday, the Supreme Court of Canada released the eagerly-anticipated decision in Daishowa-Marubeni v. R. The question before the Court was whether a reforestation obligation attached to a timber resource property should form part of the vendor’s proceeds of disposition when the property is sold.
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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