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

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

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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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Alexander Marino recently appeared on the Global Investment Voice Podcast to discuss the benefits of renouncing US citizenship on March 14, 2024.

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Alexander Marino guested on the Snowbirds US Expats Radio Podcast about the benefits of renouncing your US citizenship on January 17, 2024.

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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.

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The taxation of commission income received by a life insurance agent

On March 29, 2011, the Tax Court of Canada released its decision in Bernard Demeterio v. Her Majesty The Queen 2011 TCC 192.  The case involved Bernard Demeterio, a life insurance agent, who received life insurance commissions in the 2002 and 2003 taxation years.  Mr. Demeterio submitted that the commissions he received should not be taxable in the year of receipt (i.e. 2002 and 2003).  He felt that the commissions were not income that had been earned but instead were loans advanced to him because they were required to be paid back if the life insurance policies that he sold were cancelled within two years. [This is a rather common remuneration feature amongst life insurance sales persons and life insurance companies and is often referred to as “chargebacks”]. Mr. Demeterio submitted that the commission income should be taxable once the life insurance premiums became non-refundable in the two immediate taxation years following the year of receipt.

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2011 Federal Budget highlights: The “anti-avoidance” budget

 

On March 22, 2011, Finance Minister Jim Flaherty, introduced the 2011 Federal Budget. The Budget contains a few “goodies” but will be remembered more for the anti-avoidance provisions that it contains. The more interesting and relevant (for our clients and friends) income tax measures that were introduced in the Budget were as follows:

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The Department of Finance releases new income tax proposals in respect of deductible expenditures

On March 16, 2011, the Department of Finance released draft income tax legislation for comment.  The Department of Finance is looking for comments from the public by April 15, 2011.

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“Management fees”: The ugly

You know the cliché… there are always two sides to every story.  Well, the story painted in the recently released Tax Court of Canada case Mark A. Sochatsky v. Her Majesty the Queen 2011 TCC 41 is certainly an ugly story.

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Opportunity to get current with IRS without penalties?

As Kim recently posted, the IRS has set up a new special voluntary disclosure program for US taxpayers who have unreported income from offshore assets.  Interestingly, the IRS has indicated that, as part of the program, taxpayers may file delinquent Report of Foreign Bank and Financial Accounts (“FBAR”) forms.

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CRA audit of high-net-worth individuals and new US voluntary disclosure program

In 2008, the Organisation for Economic Cooperation and Development (“OECD”) released a discussion paper regarding their project on high-net-worth individuals.  The discussion paper was intended for public comment. Tax advisors who read the discussion paper and who work with private clients were certainly concerned about some of the comments made.  In September 2009, the OECD released a publication entitled “Engaging with High-Net-Worth Individuals on Tax Compliance”.  The publication explored “….the significant challenges to tax administration [when dealing with high-net-worth individuals] due to the complexity of their affairs, their revenue contribution, the opportunity for aggressive tax planning and the impact of their compliance behavior on the integrity of the tax system”.  Given the OECD’s activity in recent years regarding high-net-worth individuals, tax advisors (like our firm) were not surprised to see certain countries start to engage more with that group. 

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***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.

***CLICK FOR ALL NEWS***

Alexander Marino recently appeared on the Global Investment Voice Podcast to discuss the benefits of renouncing US citizenship on March 14, 2024.

***CLICK FOR ALL NEWS***

Alexander Marino guested on the Snowbirds US Expats Radio Podcast about the benefits of renouncing your US citizenship on January 17, 2024.

***CLICK FOR ALL NEWS***

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.