Alexander Marino is quoted in The Guardian article:“‘I don’t want to be part of a dictatorship’: the Americans queueing up to renounce their citizenship”, April 28, 2026.
Alexander Marino was a guest on the “This is Ottawa” CBC podcast episode titled ‘I feel alienated from my U.S. identity’ on March 23, 2026.
Alexander Marino was interviewed for the CBC news story “Dual citizens weigh Trump, taxes in decision to renounce US citizenship” on March 23, 2026.
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?”
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It’s high time – provisions should be read narrowly: Lehigh
On April 23, 2014, the Federal Court of Appeal (the “FCA”) released its decision in The Queen v Lehigh Cement Limited (“Lehigh”). The lower Court’s decision employed a broad interpretation of the anti-avoidance rule which surprised many practitioners and may have had wider implication to the interpretation of other specific anti-avoidance rules in the Act. On the appeal, the FCA revisited the issue and found that a narrow reading of the provision at issue was more appropriate. A textual focus in interpreting anti-avoidance provisions will give certainty to tax planners as they design their plans around these specific rules. However, a narrow interpretation of specific anti-avoidance provisions could increase the CRA’s reliance on the GAAR resulting in more GAAR reassessments for taxpayers.
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.
Alexander Marino is quoted in The Guardian article:“‘I don’t want to be part of a dictatorship’: the Americans queueing up to renounce their citizenship”, April 28, 2026.
Alexander Marino was a guest on the “This is Ottawa” CBC podcast episode titled ‘I feel alienated from my U.S. identity’ on March 23, 2026.
Alexander Marino was interviewed for the CBC news story “Dual citizens weigh Trump, taxes in decision to renounce US citizenship” on March 23, 2026.
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?”
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