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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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Kim G C Moody appeared on BNN, in a segment titled “‘Pandora Papers’ expose of the rich and famous is ‘sensational’ and ‘vanilla'”, BNN Bloomberg, Oct. 4, 2021

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Kim G C Moody appeared on BNN, in a segment titled “The Liberals’ proposed wealth tax is ‘littered with issues’: Tax expert.” BNN Bloomberg, Sep. 23, 2021

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Kim G C Moody is quoted in Tax Notes titled “Trudeau Clinches Third Term in Canadian Federal Election.” Tax Notes, Sep. 22, 2021 (PDF)

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Kim G C Moody is quoted in the Investment Executive on the “misleading” June 30 press release regarding Bill C-208: Investment Executive, July 20, 2021

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Bill C-208 has caused some confusion for business owners wanting to sell. Kim G C Moody joined Dave and Faisal on More Than Money (July 17, 2021), to break down what this bill is and its tax implications. Listen to the episode

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Tax evasion: The United States and the UBS affair

The recent US Internal Revenue Service suit against and settlement with Swiss bank UBS over the identity of potential tax evaders appears to be just the start of a more concerted global effort by the US to crack down on unpaid tax on offshore accounts. See New York Times article on August 20, 2009.

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Unlimited Liability Corporations (“ULCs”) and other flow through entities – The new Fifth Protocol to the Canada-United States Income Tax Convention

In the recent past, US taxpayers who wanted to invest in Canada would often do so with structures that would avoid inefficient tax results on both sides of the border.  One of the common structures that was employed in the corporate context was to utilize certain Canadian corporations that were fiscally transparent for US purposes.  In Canada, such corporations only existed in Nova Scotia (as a Nova Scotia Unlimited Liability Corporation) or in Alberta (as an Alberta Unlimited Liability Corporation).  To the extent that a US taxpayer owned, say 100% of the shares of the ULC, all of the profits of the ULC would generally be fiscally transparent for US tax purposes (meaning that the US would not respect the ULC as being a separate legal entity and would require the profits of the ULC to be included in the US taxpayer’s income directly). For Canadian purposes, the ULC was treated as a “normal” corporation for taxation purposes and thus the profits were subject to Canadian tax with such tax generally being creditable against the US tax on the ULC’s profits.  The result was the avoidance of potential inefficient tax results on an overall basis.  To the extent that the profits of the ULC were repatriated to the US parent by way of a dividend, such dividends would often be subject to “treaty benefits” which would result in a reduced withholding tax rate.

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Changes to Alberta eligible dividend tax rates

by Faizal Valli CA and Jeff Hlynski CA, CFP, TEP

On June 4, 2009 the government of Alberta quietly passed Bill 40, which contained amendments to the Alberta Personal Income Tax Act. The amendments provided for decreases to eligible dividend tax rates for individuals resident in Alberta, for 2010 and later years.

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Commissions earned on the sale of life insurance policies to self employed life insurance salespersons

By Nicolas F. Baass LL.B., LL.M. (Tax)

On May 11, 2009 the Tax Court of Canada released Justice Lucie Lamarre’s judgement in Jacques Bilodeau v. The Queen. 1 As of the time of the writing of this blog the decision was only available in French. The case dealt with the deductibility of commissions received by a life insurance salesperson on the acquisition of a life insurance policy by that salesperson.

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Recent Canada Revenue Agency administrative announcements – Home renovation tax credit, prescribed loan rate and charity guidelines

In these lazy, hazy days of summer, the tax world does not stop. The court cases, Canada Revenue Agency (“CRA”) administrative announcements and speculated policy changes continue to be announced and/or rumored. We thought you would be interested in three of the more relevant recent CRA announcements:

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GST on investment management fees

By Nicolas F. Baass  LL.B., LL.M.(Tax)

The Federal Court of Appeal decision in Canadian Medical Protective Assn. v. R. released April 16, 2009 deals with the GST status of investment management fees. 

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***CLICK FOR ALL NEWS***

Kim G C Moody appeared on BNN, in a segment titled “‘Pandora Papers’ expose of the rich and famous is ‘sensational’ and ‘vanilla'”, BNN Bloomberg, Oct. 4, 2021

***CLICK FOR ALL NEWS***

Kim G C Moody appeared on BNN, in a segment titled “The Liberals’ proposed wealth tax is ‘littered with issues’: Tax expert.” BNN Bloomberg, Sep. 23, 2021

***CLICK FOR ALL NEWS***

Kim G C Moody is quoted in Tax Notes titled “Trudeau Clinches Third Term in Canadian Federal Election.” Tax Notes, Sep. 22, 2021 (PDF)

***CLICK FOR ALL NEWS***

Kim G C Moody is quoted in the Investment Executive on the “misleading” June 30 press release regarding Bill C-208: Investment Executive, July 20, 2021

***CLICK FOR ALL NEWS***

Bill C-208 has caused some confusion for business owners wanting to sell. Kim G C Moody joined Dave and Faisal on More Than Money (July 17, 2021), to break down what this bill is and its tax implications. Listen to the episode