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  • Article

    Macro Forces Affecting Taxpayers

    A list of some of the tax forces that are currently impacting client's affairs.
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    Our Response To The CRA's Position On Creditor-Proofing Reorganizations – Part 2 (A Case Study)

    In this post, we build upon our Response to the CRA's Position on Creditor-Proofing Reorganizations blog by presenting a specific example of a creditor-proofing reorganization.
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

Trump Vs. Biden: Who Should The US Citizen Expat Be Rooting For "Tax-Wise"?

If late into the evening of November 3rd, 2020, Joseph Robinette Biden Jr can reach the 270 electoral votes needed to become the 46th President of the United States
United StatesTax
Moodys Private Client Law
Moodys Private Client Law
  • Article

    CaseNotes for February, 2020

    During 2016, Mr. Robitaille received a $40,000 cheque from his wholly-owned corporation, and Mr. Robitaille intended this amount to be a management fee includable in his income.
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    US Passes New Automatic Military Draft Legislation. Will It Drive More Young US Expats To Renounce?

    Starting December 2026, the US will automatically register eligible young men for Selective Service using government data systems, eliminating the need for self-registration. For US citizens living abroad and their children, this administrative shift introduces significant implications regarding military draft obligations, particularly for dual citizens who may have never lived in the United States. Families are increasingly examining how this development intersects with broader considerations around citize
    United StatesImmigration
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    A Proposed Senate Bill Would Force Expats To Renounce US Citizenship. Here's What You Need To Know.

    A new bill introduced by Senator Bernie Moreno (R-OH) has sparked debate and concern across the global US expat community.
    United StatesTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    The Importance Of Community (and Keeping The Spirit Of The Calgary Stampede Alive)

    Community. When you think of that word, what does it mean to you? I'm sure if I asked 100 people, I'd get 100 different answers. But if you look to the font of all wisdom...
    CanadaStrategy
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    Canadian Challenge To FATCA

    In its 2015 budget, the federal government announced a commitment to implement the OECD's common reporting standards starting in July 2017 and reaffirmed Canada's commitment to introduce draft legislation in 2015.
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    Employees Profit-Sharing Plans - A Technical Review And Update

    In 2004, I provided a technical review of employees profit sharing plans ("EPSPs") as part of a paper that I wrote for the Canadian Tax Foundation.
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    New L-1 Pilot Program For Canadians Seeking Employment In The United States

    Our firm is filled with strong and creative US and Canadian tax practitioners who spend their days creating strategic solutions for clients who desire to invest their assets ...
    CanadaImmigration
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    Canadians Looking To Sell US Real Estate: Plan In Order To Avoid Roadblocks

    In a previous blog, our firm discussed five key tax issues for Canadians that are planning to sell personally-owned US real estate.
    CanadaReal Estate and Construction
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    How To Not Respond In A Non-Knee-Jerk Fashion To US Tax Reform

    Eleven months since the US released and effectuated historical tax reform (and eleven months of listening to the Canadian Department of Finance's standard speaking point stating that they will not respond to US tax reform in a knee-jerk fashion), ...
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    How Will Past Farm Losses Be Treated After The Craig Decision?

    In Canada v. Craig, 2012 SCC 43, the Supreme Court of Canada modified the combination test for determining whether the restricted farm loss rules in section 31 of the Income Tax Act (the "Act") apply to farming losses.
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    Selected Safe Income Issues: Relevant Period, Global Computation And Allocation

    This is one of two papers covering subsection 55(2) presented at the 2017 Canadian Tax Foundation (CTF) Prairies conference.
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    Taxation Of Restrictive Covenants – Caution When Trying To Qualify For Exceptions To Full Income Inclusions!

    Our firm has written about the taxation of restrictive covenants many times before.
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    The 2017 Tax Crystal Ball

    Well, it's that time of year when people start to wind down for the holidays and get ready to spend time with family. For me, I'm not immune to that.
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    Trust Reporting Rules – Draft Legislation Released

    As part of draft legislation released on July 27, 2018, the Department of Finance moved forward with new trust reporting rules that were announced in the 2018 Federal budget.
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    Looking To Make 2026 Your Last Year Of Filing US Taxes? Start Your Renunciation Journey Today.

    Every year, as June 15 rolls around, hundreds of thousands of Americans living abroad receive the same unwelcome reminder: it's time to file US taxes again.
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    Supreme Court Rejects Trump’s Birthright Citizenship Challenge: Why Renouncing US Citizenship Remains The Optimal Tax Solution For US Expats

    The US Supreme Court's June 2026 decision upholding birthright citizenship has significant implications for American expatriates who hoped a policy change might release them from lifelong US tax obligations. For "accidental Americans" born in the US but living abroad with minimal connection to the country, the ruling confirms that citizenship—and its accompanying worldwide tax filing requirements, foreign account reporting, and estate tax exposure—remains an inescapable reality unless formally r
    United StatesTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    CRA Comments On Proposed Amendments To Subsection 55(2): A New Planning Era And New Opportunities

    It is no surprise that the proposed legislation on subsection 55(2) released on July 31, 2015 was a hot-button topic at the Canadian Tax Foundation's 67th Annual Tax Conference last week in Montreal.
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Showing 261–280 of 441 results

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