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.
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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”).
The HIRE Act and foreign asset reporting
As you may be aware, a US person (US citizen or resident, US partnership, US corporation or US estate or trust) has an obligation to file a Report of Foreign Bank and Financial Account (FBAR) if that person has a financial interest in or signature authority (or comparable authority) in one or more accounts in a foreign country if the aggregate value of those accounts exceeds $10,000 USD at any time during the calendar year. However, what you may not know is that starting with the 2011 tax year under the Hiring Incentives to Restore Employment Act of 2010 (“HIRE Act”) and Internal Revenue Code section 6038D, there is now an additional requirement for an individual who holds an interest in a “specified foreign financial asset” to disclose information on each such asset if the aggregate value of all the individual’s specified foreign financial assets exceeds $50,000 USD. This disclosure is done on a form which will be attached to the individual’s income tax return. In addition, “individual” refers to any US entity which holds directly or indirectly non-US financial assets. Lastly, if the Secretary determines that an individual has an interest in one or more “specified foreign financial assets” but fails to provide sufficient information to determine whether the $50,000 USD threshold has been met, then the aggregate value will be assumed to be greater than the $50,000 USD threshold for purposes of assessing penalties.
Social media, webcasts and other technology
We here at Moodys are not immune to the social media phenomenon that has been spreading like wildfire for the past few years. Over the past 18 months or so, Moodys has been working with advisors to try and harness the power that certain social media technology can deliver. It has been an interesting experience to say the least with our eyes being opened greatly.
Updates and Moodys LLP’s third anniversary
Well, today is Moodys LLP’s third anniversary! I can’t believe how fast time has gone by. Our firm has continued to grow, expand and add value-added services. The most recent service expansion has been US cross-border services. This has been a challenging addition given how complex the US taxation area is, but it’s also been a lot of fun and exciting given how much these services are needed. We’re committed to continuing to grow this area and our existing service offerings……expect future teammate additions soon. Of course, having a great firm is all about having great team members, partners and, of course, clients. Thanks to our clients for your continued support. Thanks to the Moodys teammates……you’re all amazing. Thanks to our law firm partner – Shea Nerland Calnan LLP – the support you provide is much appreciated. Finally, thanks to all of our suppliers….we appreciate your support.
New filing requirements for partnership returns
On September 17, 2010 the Canada Revenue Agency (the “CRA”) announced changes to its administrative policy on filing requirements for partnership information returns. The administrative changes will apply for partnership fiscal periods ending on or after January 1, 2011, so December 31, 2010 and earlier fiscal periods are not affected.
Aggressive tax proposals (“AT proposals”) draft legislation released by the Department of Finance
On August 27, 2010, the Department of Finance released the draft legislation for the AT proposals that were first announced in the Federal Budget of March 4, 2010 which our firm commented on in our March 5, 2010 blog. Various organizations such as the Society of Trust and Estate Practitioners (“STEP”) and the Canadian Tax Foundation have also since commented on the AT proposals.
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.
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