Alexander Marino is quoted in The Guardian article:“‘I don’t want to be part of a dictatorship’: the Americans queueing up to renounce their citizenship”, April 28, 2026.
Alexander Marino was a guest on the “This is Ottawa” CBC podcast episode titled ‘I feel alienated from my U.S. identity’ on March 23, 2026.
Alexander Marino was interviewed for the CBC news story “Dual citizens weigh Trump, taxes in decision to renounce US citizenship” on March 23, 2026.
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?”
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Amendments to Alberta professional corporations – Bill 53
By Nicolas F. Baass LL.B., LL.M. (Tax) and Kim G C Moody CA, TEP
Good news for Alberta professionals who are regulated by the Health Professionls Act (doctors/dentists/chiropractors/optometrists), Legal Profession Act (lawyers), Medical Profession Act and Regulated Accounting Profession Act (accountants). On October 26, 2009 Bill 53 – Professional Corporations Statutes Amendment Act, 2009 passed first reading in the Alberta Legislative Assembly. This Bill, if enacted, will have some significant repercussions on how professionals set up their business affairs in order to minimize income taxes.
Quebec’s take on fighting aggressive tax planning
By Nicolas F. Baass LL.B., LL.M. (Tax)
Why would we be writing a blog on future legislative amendments to the Quebec Taxation Act when we are Alberta tax advisors and most of our clients are in Western Canada? We believe the new Quebec proposals that are the subject of this blog may have national significance if the federal or provincial governments ever follow suit. Over the years, Quebec has been the subject of certain aggressive tax planning. It appears that Quebec has been seething over these aggressive transactions ever since and has finally come out with a heavy handed proverbial slap to the taxpayer’s face. On January 30, 2009 the Quebec Minister of Finance released a working paper entitled “Aggressive Tax Planning”. The purpose of the paper was to expose what the Quebec Minister of Finance considered to be aggressive tax planning (“ATP”) and actions being contemplated to curb ATP. Interested persons were asked to provide their comments on the Minister’s proposed actions up until April 1, 2009. The result of this consultation process was announced on October 15, 2009 with an information bulletin laying out Quebec’s initiative to combat ATP. While some of these measures are not as far reaching as feared, some of them have quite an impact on how tax planning advisory services may be provided in Quebec. The following is a summary of some of the more important legislation to be enacted:2nd anniversary, new blogsite and private corporations and the use of management fees
Tomorrow marks the second anniversary of the establishment of Moodys LLP Tax Advisors! While the last year has certainly provided economic challenges for our clients, we are extremely pleased with the services, clients and growth that our firm has had. A special thank you to the Moodys’ teammates and Shea Nerland Calnan LLP (our fantastic legal partner). A special thank you also to all of our great service providers. Moodys has some exciting new plans and service offerings that we will share with you soon!
For those of you who enjoy reading our blogs, we are pleased to announce our new blogsite at www.taxandestateplanning.com which hosts all of our blogs and has a link to a whole host of other interesting blogs. We encourage you to visit this website.
As a tax specialist firm, we work with many private corporations and their accounting and legal advisors. We see a lot of opportunities for planning and take great pleasure in working with the fabulous advisors that serve our clients.
Unfortunately, however, we often come across plans that could perhaps have been better thought out. One of the common strategies that we trip across is the use of “management fees” to reduce income of one corporation and increase the income of another corporation. Often times the payor corporation and the recipient corporation have different taxation year ends and therefore the plan is a loose attempt to try and get an income tax deferral. In some cases, advisors will recommend the use of a disassociated “Management Co” (owned by a related person) to receive management fees in an attempt to multiply access to the small business deduction (with the result being lower income tax rates on retained profits). There are a host of income tax issues that need to be considered with the use of management fees between related corporations. For example, are the management fees legitimate, are they reasonable, were they incurred for the purpose of earning from a business or property, are the management fees earned over the course of the year (and, if so, is the resulting deferral eliminated or reduced) and are GST issues properly considered?
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.
Alexander Marino is quoted in The Guardian article:“‘I don’t want to be part of a dictatorship’: the Americans queueing up to renounce their citizenship”, April 28, 2026.
Alexander Marino was a guest on the “This is Ottawa” CBC podcast episode titled ‘I feel alienated from my U.S. identity’ on March 23, 2026.
Alexander Marino was interviewed for the CBC news story “Dual citizens weigh Trump, taxes in decision to renounce US citizenship” on March 23, 2026.
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?”
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