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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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Alexander Marino recently appeared on the Global Investment Voice Podcast to discuss the benefits of renouncing US citizenship on March 14, 2024.

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Alexander Marino guested on the Snowbirds US Expats Radio Podcast about the benefits of renouncing your US citizenship on January 17, 2024.

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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.

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Kenneth Keung quoted in Investment Executive article titled “Window closing on family business transfers using Bill C-208”, published on October 10, 2023.

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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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Bill 53 proclaimed!

Further to our blog postings of November 26, 2009 and October 27, 2009, this legislation was finally proclaimed on February 4, 2010 and comes into force on March 1, 2010. 

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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.

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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: 

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Things are a’happening!

Happy belated New Year!  I hope that your holiday season (although it may now seem long forgotten) was a refreshing and wonderful time for you and your families.

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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. 

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Department of Finance responds to GST and financial services court decision

On December 14, 2009 the Minister of Finance issued a News Release and Backgrounder setting out the Government of Canada’s response to an April 2009 court decision on the application of GST to certain investment management fees.

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***CLICK FOR ALL NEWS***

Alexander Marino recently appeared on the Global Investment Voice Podcast to discuss the benefits of renouncing US citizenship on March 14, 2024.

***CLICK FOR ALL NEWS***

Alexander Marino guested on the Snowbirds US Expats Radio Podcast about the benefits of renouncing your US citizenship on January 17, 2024.

***CLICK FOR ALL NEWS***

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.

***CLICK FOR ALL NEWS***

Kenneth Keung quoted in Investment Executive article titled “Window closing on family business transfers using Bill C-208”, published on October 10, 2023.

***CLICK FOR ALL NEWS***

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