Blog + News

Insight on what’s happening in the world of tax, law and accounting so you can stay ahead.

***CLICK FOR ALL NEWS***

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.

***CLICK FOR ALL NEWS***

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

***CLICK FOR ALL NEWS***

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.

***CLICK FOR ALL NEWS***

Kenneth Keung is quoted in the Investment Executive article titled “How should trusts flow out capital gains to beneficiaries in 2024?”, July 5, 2024.

***CLICK FOR ALL NEWS***

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.

All
  • All
  • Accounting
  • Alexander Marino JD, LLM (US Tax)
  • Announcements
  • Business Law
  • Canadian Tax
  • Christmas
  • Federal Budget
  • Firm News
  • Flowcharts
  • Immigration & Travel
  • Living Abroad
  • Personal Notes
  • Publications
  • Team Profiles
  • Trust & Estate Law
  • US Citizenship Renunciation
  • US Tax
  • Webinar Recordings

The story of the cow, the pipeline and MacDonald (regarding the taxpayer’s victory involving subsection 84(2) and the GAAR)

Well, it has been quite a week… first we have a story about a runaway cow that walks up to the drive-through window at a McDonalds restaurant in Brush, Colorado. That’s pretty funny stuff, but the story of the very recently released Tax Court of Canada’s decision in MacDonald, as discussed below, is even better.

Read More

Supreme Court of Canada considers residency of a trust in St. Michael Trust Corp.


St. Michael Trust Corp. v. The Queen
is the first appeal where the Supreme Court of Canada has considered the test for residency of a trust for tax purposes. The appeal was heard merely four weeks ago.  We were surprised when printing out the Court’s judgment that its pages could be bound by a standard staple, which is exceedingly rare for a complex tax appeal.  The importance of residency status is that a Canadian-resident taxpayer, including a trust, is taxable in Canada on worldwide income.

Read More

The 2012 Federal Budget

On March 29, 2012, The Honourable Jim Flaherty, Minister of Finance released the 2012 Federal Budget.  This blog discusses some of the more important tax proposals that will affect our clients and friends.  Our blog of February 21, 2012 had some predictions as to what the Federal Budget would contain and certainly some of our predictions have come true as highlighted below.

Read More

Treaty shopping explained: Velcro Canada Inc. v. The Queen

The Canada Revenue Agency (“CRA”) recently lost in Tax Court against a taxpayer that had structured their operations to minimize Canadian tax.  The case, Velcro Canada Inc. v. The Queen, (“Velcro Canada”) is the first case since the FCA decision of Prevost Car Inc. v. the Queen (“Prevost Car”), (see our blog on March 18, 2009) that deals with the concept of “beneficial ownership” in a treaty shopping context.  The purpose of this blog is to outline how treaty shopping works and how the CRA has tried to assess against this practice. 

Read More

The upcoming 2012 Canadian Federal Budget

As mentioned in an earlier post, the Federal Budget is usually the place where most tax proposals arise. Accordingly, tax practitioners are keenly interested in the detailed Budget proposals that get released. However, as we have mentioned in earlier posts, there are also many income tax amendments / proposals and comfort letters released by the Department of Finance throughout the year.  In addition, there are hundreds of cases released by the Courts every year in Canada that affect the practice of tax. Accordingly, while it has long been the tradition by many of our peers to race to release a Federal Budget summary, our approach at Moodys is purposefully different. We will, of course, release a Budget summary but we instead, strive for thoughtful analysis and the timely release of tax information throughout the year; not just once a year. 

Read More

Some short answers / rebuttals to common tax myths

The study and practice of tax is tough. I have said it before and I’ll say it again, I believe that tax is one of the most difficult areas of practice in existence.

Read More

***CLICK FOR ALL NEWS***

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.

***CLICK FOR ALL NEWS***

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

***CLICK FOR ALL NEWS***

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.

***CLICK FOR ALL NEWS***

Kenneth Keung is quoted in the Investment Executive article titled “How should trusts flow out capital gains to beneficiaries in 2024?”, July 5, 2024.

***CLICK FOR ALL NEWS***

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.