Alexander Marino is quoted in the Newsweek article: “Thousands Renounce US Citizenship as Expatriation Figures Near Record High,” October 30, 2026.
Alexander Marino appeared on CONNECT With Sarah Crosbie on Corus Radio on August 25, 2026, to discuss to discuss US Citizenship Renunciation in wake of the Canada-US trade war.
Alexander Marino is quoted in The Guardian article:“‘I don’t want to be part of a dictatorship’: the Americans queueing up to renounce their citizenship”, April 28, 2026.
Alexander Marino was a guest on the “This is Ottawa” CBC podcast episode titled ‘I feel alienated from my U.S. identity’ on March 23, 2026.
Alexander Marino was interviewed for the CBC news story “Dual citizens weigh Trump, taxes in decision to renounce US citizenship” on March 23, 2026.
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Tax resiliency
I was catching up on my reading over the weekend and I came across a short essay published by the Harvard Business Review. Two paragraphs of the article struck a chord. They read as follows:
Canada Revenue Agency (“CRA”) trust audits: An update
Our firm’s June 21, 2010 blog (yes, that’s over two years ago), discussed the CRA’s domestic trust audit project. Our February 9, 2011 blog discussed the CRA’s high net worth audit initiative (or what the CRA calls the “Related Party Initiative” or “RPI” for short). These are two very high profile audit initiatives undertaken by the CRA. What is the status of these projects? Good question.
Employees profit-sharing plans: A technical review and update
In 2004, I provided a technical review of employees profit sharing plans (“EPSPs”) as part of a paper that I wrote for the Canadian Tax Foundation. The 2012 Federal Budget significantly changed the game. Accordingly, I thought it might be time to update my 2004 analysis.
Small-firm practitioners: How can they cope with the fast pace of change?
One of the largest sources of work for our firm is from accounting and law firms who need specialized domestic and cross-border tax advice. Such practitioners are great friends of our firm.
As the world becomes more complex, small-firm accountants and lawyers can have a very difficult time keeping up with the pace of change that occurs around them.
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.
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.
Alexander Marino is quoted in the Newsweek article: “Thousands Renounce US Citizenship as Expatriation Figures Near Record High,” October 30, 2026.
Alexander Marino appeared on CONNECT With Sarah Crosbie on Corus Radio on August 25, 2026, to discuss to discuss US Citizenship Renunciation in wake of the Canada-US trade war.
Alexander Marino is quoted in The Guardian article:“‘I don’t want to be part of a dictatorship’: the Americans queueing up to renounce their citizenship”, April 28, 2026.
Alexander Marino was a guest on the “This is Ottawa” CBC podcast episode titled ‘I feel alienated from my U.S. identity’ on March 23, 2026.
Alexander Marino was interviewed for the CBC news story “Dual citizens weigh Trump, taxes in decision to renounce US citizenship” on March 23, 2026.
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