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.
Kim GC Moody was a guest on The Current with Matt Galloway on CBC Radio, on September 22, 2025 discussing “Why can’t you get a CRA agent on the line?”
Alexander Marino appeared on CONNECT With Sarah Crosbie on Corus Radio on September 16, 2025, to discuss “Are YOU an Accidental American?”
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The “kiddie tax”: Some simple planning
With much fanfare, the “kiddie tax” was introduced into Canadian tax law effective January 1, 2000. My, how time flies. It does not seem like it was 11.5 years ago that such a tax was introduced to prevent income splitting mischief.
The proposed CA-CMA merger: Some random musings
Before we proceed the reader needs to know that the views expressed below are mine only and do not necessarily represent the views of all the accounting professionals in our firm.
Personal use property owned by a corporation
In my many years of practice, it never fails to amaze me how many people rely on non-qualified persons for advice in one of the most complex topics there is – tax planning or, as Moodys LLP likes to call it, “tax optimization”. There is no shortage of “experts” who seem to think that they understand tax. In this day and age of instant information vis-à-vis the internet, such “experts” continue to flourish and continue to dispense tax advice to their colleagues and buddies. Unfortunately, many of those people end up in our offices seeking advice when things go wrong. In many cases, such advice has led to “planning” which is a ticking time bomb waiting for nasty results should their affairs ever be reviewed.
A novel approach to subsection 75(2)
In a recent new case, Sommerer P. v. The Queen,[1] the Tax Court of Canada reinterprets the attribution rule in subsection 75(2), significantly narrowing the prior understanding of the rule’s scope. The Minister of National Revenue has appealed this decision. The case also deals with a number of other interesting tax and legal issues, which we will not discuss in the blog.
Canada Safeway Ltd. v. Alberta: GAAR and inter-jurisdictional tax planning
Canada Safeway Ltd. v. Alberta1 is one of the early court decisions2 examining the general anti-avoidance rule (“GAAR”) under the Alberta Corporate Tax Act.3 The issue was whether tax benefits resulting from a plan referred to as the “Ontario shuffle” should be denied under the GAAR to two taxpayers in the corporate group. Both taxpayers were successful in this case.
Rectification: The evolving landscape
S & D International Group Inc. v. Canada[1] is another recent case on rectification which represents a significant win for taxpayers.[2] In S&D International Group Inc., the Court broadly interpreted its equitable jurisdiction to allow taxpayers to correct transactions producing unintended tax consequences and granted a rectification order despite scant evidence of intent to avoid tax, and despite the fact that the taxpayers were under no misapprehension about the basic nature of the transaction (share repurchase).
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.
Kim GC Moody was a guest on The Current with Matt Galloway on CBC Radio, on September 22, 2025 discussing “Why can’t you get a CRA agent on the line?”
Alexander Marino appeared on CONNECT With Sarah Crosbie on Corus Radio on September 16, 2025, to discuss “Are YOU an Accidental American?”
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