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We here at Moodys are not immune to the social media phenomenon that has been spreading like wildfire for the past few years. Over the past 18 months or so, Moodys has been working with advisors to try and harness the power that certain social media technology can deliver. It has been an...
The Canada Revenue Agency (“CRA”) recently lost in Tax Court against a taxpayer that had structured their operations to minimize Canadian tax. The case, Velcro Canada Inc. v. The Queen, (“Velcro Canada”) is the first case since the FCA decision of Prevost Car Inc. v....
As mentioned in an earlier post, the Federal Budget is usually the place where most tax proposals arise. Accordingly, tax practitioners are keenly interested in the detailed Budget proposals that get released. However, as we have mentioned in earlier posts, there are also many income tax amendments...
Roy A. Berg JD. LL.M. (US Tax) & Nicholas J. Dancey JD, LL.M. (US Tax) On February 08, 2012 the IRS issued IR 2012-15, which contains proposed regulations that clarify the manner in which non-US financial institutions will find and report US persons to the IRS, which is required by the...
The study and practice of tax is tough. I have said it before and I'll say it again, I believe that tax is one of the most difficult areas of practice in existence. In my many years of being a tax specialist, there have been no shortages of "tax myths" that I have run across and dealt...
RRSPs are an extremely popular investment vehicle for Canadians. With the mild weather, it may be easy to forget it is February and the RRSP deadline is February 29th. (The deadline is usually March 1, but with 2012 being a leap year it will be the last day of February.) This RRSP...
This is not a new topic. However, it is one that we deal with time and time again....especially in recent years. Tax policy and the implementation of tax legislation in Canada is under the purview of The Department of Finance. Much of Canada's new tax legislation arises from the annual Federal...
Firstly, this is my list not yours. It is very subjective and is a reflection of my many years of experience of being a tax specialist and building a “tax only” advisory practice. Most of the practitioners that are clients and friends of our firm know their tax...
Posted by Roberto Domagas CA and Robert Worthington LL.B. Copthorne Holdings Ltd. v. Canada, 2011 SCC 63 (CanLII) is a recent decision from the Supreme Court of Canada regarding the general anti-avoidance rule (“GAAR”) and provides the much-anticipated interpretation and...
On December 15th and 16th I attended the International Taxation conference sponsored by the IRS and held in Washington DC. There were more than 700 people in attendance and the lunchtime speaker on the first day was Douglas Shulman, the Commissioner of the IRS. At the end of his prepared...