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
- 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
Barbados spousal trusts – Tax avoidance
By Marissa L. Halil LLB BCL
Once again, be warned that this blog is lengthier than usual given the importance of this topic. Antle v. The Queen 2009 TCC 465 is an interesting new case released on September 18, 2009. It involved the use of a Barbados Spousal Trust to avoid Canadian capital gains tax on the sale of shares. In Antle, the taxpayer husband rolled shares with inherent gains to a Barbados Spousal Trust. The Barbados Trust sold the shares to the beneficiary wife, who then sold them to a third party purchaser. The sale proceeds from the third party purchaser were used by the beneficiary wife to pay off the Trust. The Trust made a tax-free distribution to the beneficiary wife. The Trust was then immediately dissolved. The result was no tax was payable, either in Canada or Barbados (Barbados does not impose tax on capital gains, which is where the gain arose). Justice Miller, writing for the Tax Court of Canada, found that the Barbados Spousal Trust was not validly constituted and, even if it had been, GAAR would apply to deny any tax benefits to the taxpayer husband.Changes in non-profit corporate law
By Nicolas F. Baass LL.B., LL.M. (Tax)
According to government statistics there are approximately 161,000 not-for-profit organizations in Canada, of which 19,000 are federally incorporated. Up until now these non-profit corporations were predominantly incorporated pursuant to Part II of the Canadian Corporations Act (“CCA”).1 The CCA is largely unchanged from the date of its enactment in 1917, and as such it is cumbersome and lacks adequate provisions for corporate governance and other provisions which one would expect to find in an act regulating corporations in Canada. Bill C-4, the Canada Not-for-Profit Corporations Act (“NPCA”), provides for an overhaul of non-profit corporate law with the phased repeal of the CCA and the continuance of CCA non-profit corporations into NPCA not-for-profit corporations.A landmark new decision on how the residency of a trust is determined
By Nicolas F. Baass LL.B., LL.M. (Tax) and Kim G C Moody CA, TEP
This blog deals with a landmark new Tax Court decision released last week. Given its importance, we spill a lot more ink than our usual blog entries. Accordingly, be warned that this entry is lengthy.Tax Evasion – The United States and the UBS affair: An update
Classic rock, Regulation 105 withholding requirements and other musings
For those of you who know me, you’ll know that I personally live our firm’s branding material … I’m passionate about tax! Outside of work, people who know me also know that my taste in music is wide ranging. I’m passionate about music in general and have a soft spot for “classic rock”, with one of my favorite bands being AC/DC. This weekend, I had the pleasure of travelling to Vancouver with my two oldest children to attend their concert. It was great! A little loud … but great nonetheless!
Tax evasion: The United States and the UBS affair
The recent US Internal Revenue Service suit against and settlement with Swiss bank UBS over the identity of potential tax evaders appears to be just the start of a more concerted global effort by the US to crack down on unpaid tax on offshore accounts. See New York Times article on August 20, 2009.
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
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.