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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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.
Morality and Tax
“…there is nothing sinister in so arranging one’s affairs as to keep taxes as low as possible. Everybody does so, rich or poor; and all do right, for nobody owes any public duty to pay more than the law demands…To demand more of mortals is mere cant.”
Learned Hand in Commissioner v. Newman, 159 F2d 848 (1947).
Everywhere you look lately, the press seems to be reporting another group or person that is pontificating about the “evils” of tax avoidance and tax planning. The usual rhetoric is that corporations or individuals who plan to reduce their taxes are engaging in immoral practices since they should be paying their “fair share”.
Canadian taxation treatment of restrictive covenants – Section 56.4
Our firm has written on the Canadian taxation treatment of restrictive covenants many times. Our blogs of April 11, 2008 and July 20, 2010 are two small examples. In addition, I wrote an extensive paper for the Canadian Tax Foundation on this topic in 2008. However, some of the content of my 2008 paper is out of date given some extensive amendments to proposed section 56.4 subsequent to the release of that paper but much of it is still relevant.
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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