Alexander Marino is quoted in an article titled “Trump bump: U.S. citizenship renunciation inquiries surge in Canada, lawyers say” on CBC News, January 28, 2025.
Alexander Marino is quoted in an article titled “‘Scary’: Why US expats are tossing their citizenships – and it’s not just Trump” in The Sydney Morning Herald, November 1, 2024
Kenneth Keung is quoted in the Investment Executive article titled “Quirk in capital gains tax rules raises risks for incorporated clients,” published on July 24, 2024.
Kenneth Keung is quoted in the Investment Executive article titled “How should trusts flow out capital gains to beneficiaries in 2024?”, July 5, 2024.
Kim G C Moody, Kenneth Keung, and Christopher Ellett are quoted in the Investment Executive article titled “When is the latest clients can sell assets prior to June 25?”, published on May 17, 2024.
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Capital dividends and anti-avoidance considerations
Most accountants and lawyers who deal with Canadian private corporations know that certain amounts can be received by shareholders tax free. Specifically, tax free capital dividends can be paid to the shareholders of Canadian private corporations pursuant to subsection 83(2) of the Income Tax Act (the “Act”) which states:
How will past farm losses be treated after the Craig decision?
In Canada v. Craig, 2012 SCC 43, the Supreme Court of Canada modified the combination test for determining whether the restricted farm loss rules in section 31 of the Income Tax Act (the “Act”) apply to farming losses. We discussed this case in our August 2, 2012 blog. This may have an impact on taxpayers whose farming losses, as a result of the Craig decision, are no longer considered to be restricted farming losses and how those losses were applied in the taxation year in which they were incurred.
Canadian government moves to implement long overdue technical tax amendments
On October 24, 2012, the Minister of Finance tabled a detailed Notice of Ways and Means Motion (“NWMM”) to implement technical tax amendments. Many of the amendments were proposed approximately 10 years ago. We have previously written on how the Government of Canada develops and implements tax legislation in our February 1, 2012 blog . As we noted in that blog, the fact that there has been proposed tax legislation in existence for such a long time has been challenging. The long outstanding proposed legislation appears to be close to being passed into law and is very welcome news.
Tax in Canada and the US: The differences that really matter
Many people assume that the US and Canadian tax systems for individuals are similar. Not true. There are some important differences. Accordingly, the purpose of this article is to point out some of these important differences that can cause problems for the uninformed. By no means is this article intended to be exhaustive… simply informative.
Hot times for summer tax action: The top five
Our firm’s tax groupies often ask us what is happening in the tax world. Given that we are in the heart of the summer, we thought it would be a good time to list the top five tax matters / issues that we are waiting for. Ok… ok… tax groupies might be a bit of a stretch, but we can only hope.
Important Supreme Court of Canada case on farming losses — Win, place or show me the money
On August 1, 2012 the Supreme Court of Canada released its decision in Canada v. Craig, 2012 SCC 43. The case involved the deductibility of farming losses incurred by a taxpayer.
Alexander Marino is quoted in an article titled “Trump bump: U.S. citizenship renunciation inquiries surge in Canada, lawyers say” on CBC News, January 28, 2025.
Alexander Marino is quoted in an article titled “‘Scary’: Why US expats are tossing their citizenships – and it’s not just Trump” in The Sydney Morning Herald, November 1, 2024
Kenneth Keung is quoted in the Investment Executive article titled “Quirk in capital gains tax rules raises risks for incorporated clients,” published on July 24, 2024.
Kenneth Keung is quoted in the Investment Executive article titled “How should trusts flow out capital gains to beneficiaries in 2024?”, July 5, 2024.
Kim G C Moody, Kenneth Keung, and Christopher Ellett are quoted in the Investment Executive article titled “When is the latest clients can sell assets prior to June 25?”, published on May 17, 2024.
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