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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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Kenneth Keung is quoted in the Investment Executive article titled “How should trusts flow out capital gains to beneficiaries in 2024?”, July 5, 2024.

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Kim G C Moody, Kenneth Keung, and Christopher Ellett are quoted in the Investment Executive article titled “When is the latest clients can sell assets prior to June 25?”, published on May 17, 2024.

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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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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.

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Tax Evasion – The United States and the UBS affair: An update

Following our August 25, 2009 blog regarding the US’s efforts to gather information from UBS about American account holders who may have been hiding assets and evading US taxes, the Internal Revenue Service (IRS) last week indicated that it is setting up an elite division to handle audits of wealthy Americans suspected of offshore tax evasion. The newly created office will be within its Large and Mid-Size Business division, indicating the IRS wishes to have the audits handled by those with experience in dealing with tax treaties and cross-border business structures. As another blogger recently noted, this should encourage those who may have US information reporting requirements to seek advice and consider a voluntary disclosure to the IRS.  The IRS’s voluntary disclosure program for reporting previously unreported offshore accounts ends September 23, 2009.

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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!

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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.

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Unlimited Liability Corporations (“ULCs”) and other flow through entities – The new Fifth Protocol to the Canada-United States Income Tax Convention

In the recent past, US taxpayers who wanted to invest in Canada would often do so with structures that would avoid inefficient tax results on both sides of the border.  One of the common structures that was employed in the corporate context was to utilize certain Canadian corporations that were fiscally transparent for US purposes.  In Canada, such corporations only existed in Nova Scotia (as a Nova Scotia Unlimited Liability Corporation) or in Alberta (as an Alberta Unlimited Liability Corporation).  To the extent that a US taxpayer owned, say 100% of the shares of the ULC, all of the profits of the ULC would generally be fiscally transparent for US tax purposes (meaning that the US would not respect the ULC as being a separate legal entity and would require the profits of the ULC to be included in the US taxpayer’s income directly). For Canadian purposes, the ULC was treated as a “normal” corporation for taxation purposes and thus the profits were subject to Canadian tax with such tax generally being creditable against the US tax on the ULC’s profits.  The result was the avoidance of potential inefficient tax results on an overall basis.  To the extent that the profits of the ULC were repatriated to the US parent by way of a dividend, such dividends would often be subject to “treaty benefits” which would result in a reduced withholding tax rate.

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Changes to Alberta eligible dividend tax rates

by Faizal Valli CA and Jeff Hlynski CA, CFP, TEP

On June 4, 2009 the government of Alberta quietly passed Bill 40, which contained amendments to the Alberta Personal Income Tax Act. The amendments provided for decreases to eligible dividend tax rates for individuals resident in Alberta, for 2010 and later years.

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***CLICK FOR ALL NEWS***

Kenneth Keung is quoted in the Investment Executive article titled “How should trusts flow out capital gains to beneficiaries in 2024?”, July 5, 2024.

***CLICK FOR ALL NEWS***

Kim G C Moody, Kenneth Keung, and Christopher Ellett are quoted in the Investment Executive article titled “When is the latest clients can sell assets prior to June 25?”, published on May 17, 2024.

***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.