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?”
Alexander Marino appeared on The Ben Mulroney Show on Corus Radio on September 16, 2025, to discuss “Have You Heard About Accidental Americans?”
Alexander Marino appeared on the Jim Richards Show on Newstalk 1010 in Toronto on September 4, 2025 to discuss “Why are some Americans renouncing their US citizenship?”
Kim G C Moody has authored the article, “The tax hit to Canadians from Trump’s ‘big beautiful’ bill could be tremendous” in The Financial Post, May 27, 2025.
- All
- Accounting
- Alexander Marino JD, LLM (US Tax)
- Announcements
- Business Law
- Canadian Tax
- Christmas
- Federal Budget
- Firm News
- Flowcharts
- Immigration & Travel
- Living Abroad
- Personal Notes
- Publications
- Team Profiles
- Trust & Estate Law
- US Citizenship Renunciation
- US Tax
- Webinar Recordings
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.
Possible US tax cut deal
On December 6, 2010, President Barack Obama of the United States announced a potential agreement with the opposition Republicans that would result in an extension of the Bush era tax cuts and a compromise on the US estate tax for two years which appears to commence January 1, 2011. Of major interest to clients and friends of our firm is that the US estate tax, pursuant to the terms of the deal, would have a top tax rate of 35% and a $5M exemption for US citizens. The proposed provisions of the US estate tax appear to be what the Republicans were hoping for (and better than the 2009 estate tax rate of 45% and the exemption of $3.5M) and therefore this appears to be a significant concession on the Democrat part. It has been reported that Obama was not happy with the estate tax compromise. In addition, long term capital gains and dividend rates are to remain at 15%. Both rates are scheduled to rise if a deal is not reached.
Federal Court of Appeal decision in the Garron Family Trust case: How the residency of a trust is determined
On November 17, 2010, the long awaited decision was released by the Federal Court of Appeal (“FCA”) in St. Michael Trust Corp, as Trustee of the Fundy Settlement v. Her Majesty The Queen and St. Michael Trust Corp., as Trustee of the Summersby Settlement v. Her Majesty The Queen (“Garron Family Trust”).
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?”
Alexander Marino appeared on The Ben Mulroney Show on Corus Radio on September 16, 2025, to discuss “Have You Heard About Accidental Americans?”
Alexander Marino appeared on the Jim Richards Show on Newstalk 1010 in Toronto on September 4, 2025 to discuss “Why are some Americans renouncing their US citizenship?”
Kim G C Moody has authored the article, “The tax hit to Canadians from Trump’s ‘big beautiful’ bill could be tremendous” in The Financial Post, May 27, 2025.
Moodys Private Client Blog + News in Your Inbox
Never miss a major development that might impact your bottom line with the best of our blog sent direct.