Alexander Marino is quoted in the Newsweek article: “Thousands Renounce US Citizenship as Expatriation Figures Near Record High,” October 30, 2026.
Alexander Marino appeared on CONNECT With Sarah Crosbie on Corus Radio on August 25, 2026, to discuss to discuss US Citizenship Renunciation in wake of the Canada-US trade war.
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.
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Trick or treaty: Are Canadians next as IRS takes historic first step?
Canadians know that their proximity to the US presents both risk and opportunity. One risk that has always been hard to quantify is the risk that the IRS and CRA will cooperate to enforce each others’ tax laws with respect to assets and information on both sides of the border. Recently, the likelihood of this cooperation increased significantly. For the first time, the US government has used a powerful device in support of a treaty-partner government to obtain financial data.
Pitfalls in Canada / US cross-border partnership compliance: Treatment of partnership debt
Since joining the cross border team at Moodys, I’ve had opportunities to help clients navigate US tax law and hear “O Canada” even when neither the Flames nor the Oilers are in town. For US purposes, allocations of US partnership income are reported to the IRS on a Form K-1 issued to the partners in the partnership. In Canada, the corresponding form is a Form T5013. I’ve also learned that (mimicking the mph/kmh conversion of speedometers) many Canadian accountants and taxpayers simply report their US partnership income to the CRA by converting the US dollar amounts on a K-1 to Canadian dollar amounts on their T1 or T2 (or corresponding form). This practice, although common, ignores important differences between the two sets of tax laws and can have legal ramifications.
Macro forces affecting taxpayers
I’ve said it before and I’ll say it again…the tax profession is extremely difficult. Like society, it is continuously changing and such changes challenge taxpayers and their advisors to keep up to date and respond proactively. In the past, many people in need of tax advice would simply turn to their accountants given the fact that many accountants are schooled in tax return preparation and therefore, by extension, such people assume that accountants are tax experts. However, tax return preparation and tax advisory services are truly two different service areas.
The devil’s in the details: The new form T1135 is released
Earlier this week, the CRA released the revised Foreign Income Verification Form (“T1135”) as had previously been announced by the Federal government in their 2013 Budget. Consistent with our blog posted on March 26, 2013, taxpayers are now required to report additional information which makes the T1135 more comparable to its US cousin – the FBAR.
Underwater part II: Additional taxpayer relief from the CRA?
The recent announcement by Ministers Shea and Kenney yesterday in a press release (the “Press Release”) is much welcomed by Albertans as the Province has been hit by the worst flooding in its recent history. However, the Press Release is ambiguous as to exactly which taxpayers and what filings will qualify for the relief measures announced.
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.
Alexander Marino is quoted in the Newsweek article: “Thousands Renounce US Citizenship as Expatriation Figures Near Record High,” October 30, 2026.
Alexander Marino appeared on CONNECT With Sarah Crosbie on Corus Radio on August 25, 2026, to discuss to discuss US Citizenship Renunciation in wake of the Canada-US trade war.
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.
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