Alexander Marino recently appeared on the Global Investment Voice Podcast to discuss the benefits of renouncing US citizenship on March 14, 2024.
Alexander Marino guested on the Snowbirds US Expats Radio Podcast about the benefits of renouncing your US citizenship on January 17, 2024.
Kenneth Keung and Evan Crocker are quoted in Investment Executive article titled “CRAʼs 10% interest rate on overdue tax raises risks“, published on November 13, 2023.
Kenneth Keung quoted in Investment Executive article titled “Window closing on family business transfers using Bill C-208”, published on October 10, 2023.
Kim G C Moody is quoted in the Tax Notes article titled “Canada’s Supreme Court Upholds GAAR Application in Deans Knight”, May 30, 2023
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Do you own US securities?
Do you own US securities (or other foreign stocks) in your personal portfolio? Does your corporation own US securities (or other foreign stocks)? If so, then pay careful attention to the information below.
The “kiddie tax”: Some simple planning
With much fanfare, the “kiddie tax” was introduced into Canadian tax law effective January 1, 2000. My, how time flies. It does not seem like it was 11.5 years ago that such a tax was introduced to prevent income splitting mischief.
The proposed CA-CMA merger: Some random musings
Before we proceed the reader needs to know that the views expressed below are mine only and do not necessarily represent the views of all the accounting professionals in our firm.
Personal use property owned by a corporation
In my many years of practice, it never fails to amaze me how many people rely on non-qualified persons for advice in one of the most complex topics there is – tax planning or, as Moodys LLP likes to call it, “tax optimization”. There is no shortage of “experts” who seem to think that they understand tax. In this day and age of instant information vis-à-vis the internet, such “experts” continue to flourish and continue to dispense tax advice to their colleagues and buddies. Unfortunately, many of those people end up in our offices seeking advice when things go wrong. In many cases, such advice has led to “planning” which is a ticking time bomb waiting for nasty results should their affairs ever be reviewed.
A novel approach to subsection 75(2)
In a recent new case, Sommerer P. v. The Queen,[1] the Tax Court of Canada reinterprets the attribution rule in subsection 75(2), significantly narrowing the prior understanding of the rule’s scope. The Minister of National Revenue has appealed this decision. The case also deals with a number of other interesting tax and legal issues, which we will not discuss in the blog.
Canada Safeway Ltd. v. Alberta: GAAR and inter-jurisdictional tax planning
Canada Safeway Ltd. v. Alberta1 is one of the early court decisions2 examining the general anti-avoidance rule (“GAAR”) under the Alberta Corporate Tax Act.3 The issue was whether tax benefits resulting from a plan referred to as the “Ontario shuffle” should be denied under the GAAR to two taxpayers in the corporate group. Both taxpayers were successful in this case.
Alexander Marino recently appeared on the Global Investment Voice Podcast to discuss the benefits of renouncing US citizenship on March 14, 2024.
Alexander Marino guested on the Snowbirds US Expats Radio Podcast about the benefits of renouncing your US citizenship on January 17, 2024.
Kenneth Keung and Evan Crocker are quoted in Investment Executive article titled “CRAʼs 10% interest rate on overdue tax raises risks“, published on November 13, 2023.
Kenneth Keung quoted in Investment Executive article titled “Window closing on family business transfers using Bill C-208”, published on October 10, 2023.
Kim G C Moody is quoted in the Tax Notes article titled “Canada’s Supreme Court Upholds GAAR Application in Deans Knight”, May 30, 2023
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