ArticleMacro Forces Affecting TaxpayersA list of some of the tax forces that are currently impacting client's affairs. CanadaTaxMoodys Private Client Law
ArticleOur 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.CanadaTaxMoodys Private Client Law
ArticleCaseNotes for February, 2020During 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.CanadaTaxMoodys Private Client Law
ArticleUS 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 citizeUnited StatesImmigrationMoodys Private Client Law
ArticleA 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 StatesTaxMoodys Private Client Law
ArticleThe 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...CanadaStrategyMoodys Private Client Law
ArticleCanadian Challenge To FATCAIn 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. CanadaTaxMoodys Private Client Law
ArticleEmployees Profit-Sharing Plans - A Technical Review And UpdateIn 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. CanadaTaxMoodys Private Client Law
ArticleNew L-1 Pilot Program For Canadians Seeking Employment In The United StatesOur 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 ...CanadaImmigrationMoodys Private Client Law
ArticleCanadians Looking To Sell US Real Estate: Plan In Order To Avoid RoadblocksIn 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 ConstructionMoodys Private Client Law
ArticleHow To Not Respond In A Non-Knee-Jerk Fashion To US Tax ReformEleven 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), ...CanadaTaxMoodys Private Client Law
ArticleHow 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. CanadaTaxMoodys Private Client Law
ArticleSelected Safe Income Issues: Relevant Period, Global Computation And AllocationThis is one of two papers covering subsection 55(2) presented at the 2017 Canadian Tax Foundation (CTF) Prairies conference. CanadaTaxMoodys Private Client Law
ArticleTaxation 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.CanadaTaxMoodys Private Client Law
ArticleThe 2017 Tax Crystal BallWell, 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. CanadaTaxMoodys Private Client Law
ArticleTrust Reporting Rules – Draft Legislation ReleasedAs 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. CanadaTaxMoodys Private Client Law
ArticleLooking 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.CanadaTaxMoodys Private Client Law
ArticleSupreme Court Rejects Trump’s Birthright Citizenship Challenge: Why Renouncing US Citizenship Remains The Optimal Tax Solution For US ExpatsThe 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 rUnited StatesTaxMoodys Private Client Law
ArticleCRA Comments On Proposed Amendments To Subsection 55(2): A New Planning Era And New OpportunitiesIt 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.CanadaTaxMoodys Private Client Law