Alexander Marino recently appeared on the Global Investment Voice Podcast to discuss the benefits of renouncing US citizenship on March 14, 2024.
Alexander Marino guested on the Snowbirds US Expats Radio Podcast about the benefits of renouncing your US citizenship on January 17, 2024.
Kenneth Keung and Evan Crocker are quoted in Investment Executive article titled “CRAʼs 10% interest rate on overdue tax raises risks“, published on November 13, 2023.
Kenneth Keung quoted in Investment Executive article titled “Window closing on family business transfers using Bill C-208”, published on October 10, 2023.
Kim G C Moody is quoted in the Tax Notes article titled “Canada’s Supreme Court Upholds GAAR Application in Deans Knight”, May 30, 2023
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Miscellaneous updates: Alberta Budget, Supreme Court to hear new GAAR decision and other tidbits
The tax world moves quickly. This blog entry will highlight a few miscellaneous updates that are of relevance to most of our friends and clients.
Interest deductibility under the Canadian Income Tax Act: Meaning of “payable in respect of the year”
In the recent decision of Collins v. The Queen, the Federal Court of Appeal clarifies the meaning of “an amount payable in respect of the year” – one of the requirements for interest deductibility under paragraph 20(1)(c) of the Income Tax Act (the “Act”). Specifically, in order for interest to be deductible under paragraph 20(1)(c) of the Act, there must be:
Things are a’happening!
The Queen v. Remai – A new take on “arm’s length”
The Federal Court of Appeal has recently confirmed that a taxpayer and a company controlled by the taxpayer’s nephew are considered to “act at arm’s length” in a transaction where the nephew’s company purchases promissory notes from a charity controlled by the taxpayer only to help the taxpayer solve a tax problem.
Department of Finance responds to GST and financial services court decision
Resolving Unintended Tax Consequences – Rectification, Rescission and Mistake
Income tax is complicated. As such, mistakes in transactions are liable to occur from time to time, especially when professional advisors do not consult tax specialists prior to undertaking transactions. The Court of Queen’s Bench of Alberta (“QBA”) has added another arrow to taxpayers’ quivers when mistakes lead to unintended tax consequences. In Stone’s Jewellery Ltd. v. Arora 2009 ABQB 656, a well thought out and structured judgment by Madam Justice Strekaf, the taxpayer sought an order to rectify or rescind two transactions involving the transfer of land that resulted in the unanticipated assessment of more than $6 million in taxes. The Canada Revenue Agency (“CRA”) opposed the taxpayer’s action.
Alexander Marino recently appeared on the Global Investment Voice Podcast to discuss the benefits of renouncing US citizenship on March 14, 2024.
Alexander Marino guested on the Snowbirds US Expats Radio Podcast about the benefits of renouncing your US citizenship on January 17, 2024.
Kenneth Keung and Evan Crocker are quoted in Investment Executive article titled “CRAʼs 10% interest rate on overdue tax raises risks“, published on November 13, 2023.
Kenneth Keung quoted in Investment Executive article titled “Window closing on family business transfers using Bill C-208”, published on October 10, 2023.
Kim G C Moody is quoted in the Tax Notes article titled “Canada’s Supreme Court Upholds GAAR Application in Deans Knight”, May 30, 2023
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