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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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.
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.
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.
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.
A mild RRSP season – Except for the advantage rules
RRSPs are an extremely popular investment vehicle for Canadians. With the mild weather, it may be easy to forget it is February and the RRSP deadline is February 29th. (The deadline is usually March 1, but with 2012 being a leap year it will be the last day of February.) This RRSP season, taxpayers and their advisors should be aware of a change in the RRSP rules enacted as a result of the 2011 Federal Budget. These new “advantage rules” target tax avoidance schemes and other structures that most taxpayers would not be involved in, but these rules also set a trap for the unwary. If the advantage rules apply, the Canada Revenue Agency (“CRA”) may impose a penalty tax of 100%. In general terms, this 100% tax is on the amount of the “advantage”, which may be the entire value of the investment.
Filing on the basis of proposed tax legislation
This is not a new topic. However, it is one that we deal with time and time again… especially in recent years.
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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