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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“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.
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.
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.
Moodys Mobile iPhone/iPad app released!
We are excited to announce that Moodys LLP Tax Advisors has developed an innovative way to keep you up-to-date with the most recent tax developments. Yesterday, we unveiled our iPhone/iPad application for you to download for free on the Apple App Store.
Succession planning for the private client
The news yesterday that Steve Jobs was taking a medical leave from Apple and the coincidental news received by our firm that a good friend and colleague was diagnosed with cancer lead me to think that, of course, life is very fragile and certainly a gift. It also reminded me that succession planning is very critical when dealing with the affairs of a private client.
US tax updates
2010 Tax Relief Act
Last week was a monumental week for US tax practitioners. On Friday, December 17, 2010, President Obama signed into law the Tax Relief, Unemployment Insurance Reauthorization and Job Creation Act of 2010 (affectionately known as the “2010 Tax Relief Act” or “TRUIRJCA”). While it does not provide long-term certainty, Americans (and Canadians with permanent establishments in the US) can at least be assured that for the next two years, individual and corporate tax rates will remain at 2001 levels. Additionally, dividend rates (which were scheduled to increase to ordinary income rates) and capital gains rates (scheduled to increase to 20 percent) will likewise remain at the 15 percent 2001 rate. Other notable changes to the income tax include an increase in the exemption amount for the alternative minimum tax and a decrease to the employee-share of a portion of Social Security taxes from 6.2 percent to 4.2 percent. Finally, businesses are allowed a 100-percent deduction for qualified property purchased between September 9, 2010, and December 31, 2011, that they were previously required to amortize and depreciate.
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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