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  • Article

    Canadians Beware! United States Limited Liability Companies May Be Hazardous To Your (Tax) Health

    A discussion on what Canadians should consider before using US LLCs as a vehicle to any US investments.
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    Recent Court Decisions - May 2014

    The last year has provided no shortage of exciting and interesting tax cases that tax practitioners can learn from.
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    Tax Future Shock For Small-Firm Practitioners - Dealing With The Fast Pace Of Change*

In 1970, the futurist Alvin Toffler wrote his landmark book entitled "Future Shock."
CanadaTax
Moodys Private Client Law
Moodys Private Client Law
  • Article

    Impact Of The Supreme Court Of Canada's Decision In Vavilov On Tests To Be Applied In Judicial Reviews Of Administrative Decisions

    On December 19, 2019, the Supreme Court of Canada delivered its reasons for judgement in Canada (Minister of Citizenship and Immigration)
    CanadaLitigation, Mediation & Arbitration
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    International Estate Planning After US Tax Reform

    During the 2016 U.S. presidential campaign then candidate Donald J. Trump and the Republican National Committee ("RNC") outlined similar plans to repeal the U.S. estate and gift tax regimes.
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    18 Lessons Learned From The Experience Of The July 18, 2017 Private Corporation Tax Proposals

    It's the 199th day in the Gregorian calendar for non-leap years.
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Video

    Our "Tax Take" On Canada's COVID-19 Economic Response Plan (Video)

    Today, the federal government announced Canada's COVID-19 Economic Response Plan (the "Plan"), an $82 billion support plan for individuals and businesses in response to the COVID-19 crisis.
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    Subsection 55(2) – The Road Ahead

    Subsection 55(2) of the Act2 was introduced on December 11, 1979, and until now, this provision of the Act has, by and large, remained the same.
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    Lesson From The FCA's Decision In Paletta: Seek A Legal Opinion To Obtain Sound Advice – Don't Rely On Informal Communications

    As was stated by Alexander Pope in his poem An Essay on Criticism composed in 1709, "A little learning is a dangerous thing".
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    Updated IRS Streamlined Filing Pogram: Snowbirds Beware

    On October 8, 2014, the IRS issued FAQs clarifying its amnesty programs for non-compliant taxpayers who want to catch-up on their U.S. tax filing obligations.
    United StatesTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    CaseNotes For December, 2019

    Barrett claims that he paid $27,333 in legal fees in respect to the three legal actions.
    CanadaLitigation, Mediation & Arbitration
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    If It Quacks Like A Partnership, It Is A … Corporation?

    At the Canada Revenue Agency ("CRA") Roundtable session during the International Fiscal Association Conference on May 28, 2015, the CRA was once again asked to comment on the issue of foreign entity classification.
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    Renouncing Your U.S. Citizenship: Failed Amendment May Signal That Now Is The Time To Get Out!

    If you are one of the many U.S. citizens contemplating renouncing your U.S. citizenship, Congress has sent fairly clear messages that now, as opposed to later, may be the right time to get out of the club.
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    The 2014 Federal Budget – Our Tax "Free" Comments

    Today, Finance Minister James Flaherty delivered his 10th Federal Budget.
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    Why The Alberta Budget Suggests That Alberta Resident Corporations May Want To Pay Out Retained Earnings Before January 1, 2021*

    Canada's tax regime on corporate and dividend income is based on the integration theory.
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    Residence Of Individuals

    The governments of Canada are facing increased scrutiny and criticism in respect of the growing deficits that have been accumulated at both the federal and provincial levels.
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    Introducing CaseNotes

    As tax practitioners, a good chunk of our careers are spent keeping up-to-date on changes in tax law. Changes can arise from legislative amendments, case law that helps to interpret complex
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    RRSP Over-Contributions: No Mercy, No Relief

    The Federal Court of Appeal's recent decision of Patrick Connolly v Minister of National Revenue (herein "Connolly v. MNR") highlights the serious onus the taxpayer...
    CanadaEmployment and HR
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    Renouncing US Citizenship Or Giving Up A Green Card In The Gulf: Why And How To Consider It

    US citizenship or permanent resident status allows access to the largest economy in the world.
    United StatesImmigration
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    Federal Tax Rate Increases For Canadians

    On December 7, 2015, Canada's new Finance Minister, Bill Morneau, tabled measures to reduce the federal individual income tax rate for the $45,282 to $90,563 tax bracket from 22% to 20.5%.
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Showing 381–400 of 441 results

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