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
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US tax changes
As most readers know, Canada’s system of taxation is one that will tax based upon residency. To the extent that you are a resident of Canada, you will generally pay Canadian income tax on your worldwide sources of income. To the extent that you are a non-resident of Canada, only certain types of income (such as Canadian source income or dispositions of taxable Canadian property) will be subject to Canadian income tax. Most of the countries in the world have a similar system of taxation as that in Canada where the primary tax basis is that of residency.
Small change to the eligible dividend rules
On July 14, 2008, The Department of Finance released a package of proposals to amend the Income Tax Act for various measures. Included in the package was a small amendment that proposes to tinker with the eligible dividend rules.
Capital gains vs. income
One of the more common income tax matters that Moodys LLP Tax Advisors advises on is whether or not a disposition (or a proposed disposition) of property will result in a capital gain (half of which is taxable), or will be fully taxed as income. Taxpayers often take for granted that dispositions of property will be treated as capital gains.
Supreme Court decision: McLarty – Contingent liabilities
On May 22, 2008, the Supreme Court of Canada released its decision in the McLarty matter. The issue before the Court was whether Mr. McLarty’s liability under a promissory note that was owing by him upon the acquisition of a certain oil and gas property was an absolute as opposed to a contingent liability. To the extent that the promissory note was a contingent liability, no deduction would be allowed by Mr. McLarty for such portion of the otherwise oil and gas expense deduction. The other matter before the Court was whether or not McLarty was dealing at arm’s length with the vendor when he acquired the property. To the extent that he was not dealing in an arm’s length fashion with the vendor then the acquisition of such property would be required to be made at fair market value which the CRA had argued was much less than its original acquisition price.
Tax treaty interpretation case: Prevost Car Inc.
On April 22, 2008, the important decision of Prevost was released by the Tax Court of Canada. The facts in Prevost were quite straightforward:
Personal tax season over
Yes! It’s over! As a tax practitioner, many people who talk to me during April will often comment that I must be very busy since this is “harvest season”. While there’s no doubt that many tax practioners are often busy in April, Moodys’ practice does not focus on personal tax preparation.
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
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