Canadian Tax

If you were hoping Budget 2026 would finally deliver the comprehensive tax reform that economists, tax practitioners, business groups and think tanks have been urging for years, keep waiting. What you get instead is 532 pages built around a collection of simplification measures, some genuinely welcome, which Ottawa calls “the most ambitious tax simplification effort…

For US citizens living abroad, paying tax in your country of residence does not necessarily mean you are finished paying tax. Two recent US court decisions have delivered a stark reminder of that reality. On August 31, 2026, the US Court of Appeals for the Federal Circuit ruled in Estate of Bruyea v. United States…

The following blog was written by our Summer Student, Dummie Abdul. Before I joined Moodys Private Client as a 2L (the second year of a three-year Juris Doctor [JD] program) summer student, my only familiarity with Immigration Law was a basic understanding of practice areas such as family sponsorship, refugee protection, and asylum procedures. What…

For many Americans with Canadian roots, Bill C-3 represents an extraordinary opportunity. The new legislation expands access to Canadian citizenship by descent, allowing many individuals with Canadian parents, grandparents, and even more distant Canadian ancestors to claim Canadian citizenship where previous rules prevented them from doing so. The legislation removes Canada’s former “first-generation limit” that…

On June 30, 2026, the US Supreme Court upheld birthright citizenship, rejecting President Donald Trump’s attempt to restrict automatic citizenship for children born in the United States to parents who were undocumented or in the country temporarily. The decision reaffirmed the long-standing interpretation that nearly all individuals born on US soil are US citizens at…

Senator Elizabeth Warren (D-MA) has reintroduced legislation aimed at imposing new taxes on America’s wealthiest households. This proposed Ultra-Millionaire Tax Act (“UMT Act”) (similar to the first bill she introduced in 2021) would impose a 2% annual tax on the net worth of households and trusts exceeding $50 million, along with an additional 1% tax…

In December 2026, a massive shift in US policy will take effect: eligible young men will be automatically registered for Selective Service. The Selective Service System is an independent US government agency responsible for maintaining a database of individuals who could be called upon in the event of a national military draft. While a draft…

On December 15, 2025, the Government of Canada passed Bill C-3, An Act to amend the Citizenship Act, reforming the present Citizenship Act to change the first-generation limit on citizenship by descent. Before Bill C-3, Canadian citizenship by descent was limited to the first generation born outside Canada. Now, those previously impacted by this limit…

Will Lowered Renunciation Fees Lengthen Wait Times? Yes! On March 13, after a years-long court battle, the Department of State announced it will be reducing the fee to renounce U.S. citizenship. The Department originally notified the court hearing the lawsuit of their “intent” to lower the fee on January 6, 2023, but never finalized the…

If you had to guess, what do you think the following individuals have in common? The billionaire co-founder of Facebook, Eduardo Saverin; the only American member of Monty Python, Terry Gilliam; Former Prime Minister of the United Kingdom, Boris Johnson; Director of “The Maltese Falcon” and “The Treasure of the Sierra Madre,” John Huston; Founder…

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. For many, it’s not just a box to check off. It’s a stressful, expensive, and often overwhelming process. Tracking down foreign account statements, converting currency, understanding complex US and…

A new bill introduced by Senator Bernie Moreno (R-OH) has sparked debate and concern across the global US expat community. His proposal? Eliminate the legal recognition of dual citizenship in the United States. Under the proposed legislation, anyone holding US citizenship and another nationality would have just one year to choose: forfeit their foreign nationality…

A massive shift is taking place among US citizens living abroad: nearly half are now considering renouncing their US citizenship. According to a 2025 survey by an international tax consultancy, the percentage of overseas Americans considering renunciation has surged from 30% to 49% between 2024 and 2025. While headlines often focus on politics, the real…

If you were to only pay attention to the news, you’d think no Canadians were currently looking to move to the US. We’ve got Trump and Carney in diplomatic fisticuffs and US Immigration and Customs Enforcement with boots on the ground in many major US cities. So, why is the E-2 still a safe bet…

Well, if you were expecting a big tax change budget, you’ll be disappointed.  But if you’re a fan of big government spending shrouded around the use of the phrase “investments” vs using the plain language of “spending”, then this is the budget for you.  In addition, if you believe huge government intervention into the economy…

In an unexpected change to long-standing policy, on September 1, 2025, the U.S. Consulates in Canada will no longer waive visa appointment attendance for dependent children under the age of 14. Traditionally, only adult applicants aged 80 or younger and dependent children aged 14 or older were required to attend E-2 visa appointments. If E-2S…

On July 4, 2025, President Donald Trump signed into law the One Big Beautiful Bill Act, which is by far the most significant US tax legislation since the 2017 Tax Cuts and Jobs Act. This new legislation introduced numerous major changes, including the extension of 2017 tax cuts, implementation of new tax deductions for certain…

Every year, as June 15 rolls around, thousands of Americans living abroad receive the same unwelcome reminder: it’s time to file US taxes again. For many, it’s not just a box to check off. It’s a stressful, expensive, and often overwhelming process. Tracking down statements, converting currency, understanding complex US tax rules, praying you don’t…

When the white smoke emerged, and Robert Prevost became Pope Leo XIV on May 8, 2025, he didn’t just assume the spiritual leadership of over a billion Catholics. He also made history as the first pope to be a citizen of the United States and, thereby, subject to its tax code. That singular detail—his US…

In an unprecedented and disheartening move, the US has ordered the suspension of student and exchange visitor visa (including F, M, and J visas) processing as the administration ramps up its social media vetting process, according to a diplomatic cable, first reported by Politico, issued by US Secretary of State, Marco Rubio. Issued under the…

In the wake of Donald Trump’s 2024 election victory, many US expats are taking a hard look at their American citizenship—and deciding that renunciation may be their best option. According to a recent CBC News article, US consulates in Canada have seen a surge in inquiries from American expats looking to cut ties with the…

If you’re a Canadian looking to snowbird or head south for a few months, you may have seen the news that beginning April 11, 2025, foreign nationals preparing to travel to the US for an extended period should be prepared to comply with new registration requirements ordered by the Trump Administration. Registration Requirement The Alien…

In a February 25th press conference, the Trump Administration announced plans to introduce a ‘Gold Card’ Program that would provide high-net-worth individuals permanent residency and a pathway to citizenship for $5 million. The announcement created ripples of confusion, including those either in the final stages of making an investment into an EB-5 Regional Center or…

Renouncing your US citizenship or terminating your Green Card is a significant decision for you and your family. Our team of experienced US lawyers has unparalleled experience in guiding clients through this process successfully. We have handled more than 6,000 renunciations and Green Card terminations — more than any other firm in the world —…

On August 6, 2024, Minister of Employment, Workforce Development and Official Languages, Randy Boissonnault announced a reduction in the number of temporary foreign workers, as well as strengthened compliance measures for the Temporary Foreign Worker (“TFW”) Program. These measures are a direct response to current Canadian labour market conditions, intended to ensure that qualified Canadian…

In the second installment of our “Practical Immigration” blog series, we are going to address the US Centers for Disease Control and Prevention’s (“CDC”) new rules for individuals travelling to the US with their dogs, whether for a short visit or long-term stay. According to the CDC, the new dog importation rules are intended to…

A combination of complex tax requirements and greater dissatisfaction with governmental policies is pushing more US expats towards renouncing their US citizenship. Recent surveys highlight the significant burden and challenges posed by the US tax system, particularly the requirements to report income and bank accounts in their home country under laws like the Foreign Account…

In this first installment of our “Practical Immigration” blog series, we are going to address one of the questions our clients most frequently ask “So now that I have my visa and am ready to move to the US, what happens to my car?” Our team has had to figure this answer out for ourselves…

The E-2 Treaty Investor Visa Program offers a flexible and viable pathway for aspiring Canadian entrepreneurs and investors looking to establish or purchase a business in the United States. It’s specifically designed for individuals from countries with which the United States maintains a treaty of commerce and navigation, allowing them to invest significant capital in…

In the recent fiscal year 2025 budget proposal from the Biden administration, there has been a notable push towards increasing tax rates, particularly on capital gains, which could have significant implications for US citizens living around the world. The proposal introduces a graduated taxing structure, with further modifications to include an increase to a 44.6% capital gains…

On April 16, 2024, the government of Canada released its Budget 2024.  Overall, this budget can be characterized as a very heavy spending budget with continued large deficits, no fiscal anchor, increasing public debt charges (now estimated to be a whopping $54.1 billion for the upcoming year…yes, that’s more than $1 billion per week) and…

So, You Wanna Be a Canadian? Since the signing of the Immigration Act, 1976 into legislation almost 50 years ago, Canada has become a world leader in welcoming new migrants from across the globe. The Act was the first piece of legislation to clearly outline Canadian immigration policies and objectives, which ultimately removed broad discretionary…

The weeks and months leading up to June 15 are typically referred to as tax season for the more than eight million US citizens living abroad. This time of year can also feel a lot like Groundhog Day. That’s because US expats are reminded yearly of the cost of maintaining their US citizenship, even though…

The latest data from USCIS is in, and suggests that the EB-5 Immigrant Investor Program is alive and growing healthier by the quarter. U.S. Citizenship and Immigration Services (USCIS) recently released filing and processing statistics for the 4th quarter of the 2023 fiscal year, which included encouraging signs for the EB-5 Program. New filing numbers…

In a recent survey, one in five US expats (20%) is considering or planning to renounce their US citizenship. What’s the main reason? The headaches associated with filing US taxes, the complexities of US tax laws, and owing US tax. So far, in 2023, we have seen a big jump in the number of people…

This blog article is based on a CALU Report published by the Conference for Advanced Life Underwriting and authored by Kenneth Keung and Jason Lau.  It is reproduced with their permission.   Introduction Section 84.1 of the Income Tax Act [1] as we know it today got its start in 1985, concurrent with the introduction…

Air travel can be stressful. Rising airfares and hotel costs, flight cancellations, pilot strikes, long security wait lines, and lost luggage are just some of the headaches that travellers face as more and more people head to the US. According to the US Travel Association, flight demand was up by 12% in July alone. US…

On September 27, 2023, Secretary of Homeland Security Alejandro N. Mayorkas and Secretary of State Antony J. Blinken announced in a joint statement that the US would be admitting Israel into the Visa Waiver Program (VWP). This expansion will be welcome news to Israelis wishing to visit the US as it aims to strengthen further…

The alternative minimum tax (“AMT”) was first introduced in 1986 to ensure that individuals and trusts pay some amount of minimum tax where they otherwise would not (or would pay what was perceived to be an insufficient amount) due to tax preferred forms of income such as gains from qualified small business corporation shares, qualified…

On Thursday, July 13, 2023, the Supreme Court of Canada handed down a landmark decision to dismiss an application for leave to appeal a challenge to the constitutionality of Part XVIII of the Canadian Income Tax Act. The decision obliterated any hope of striking down FATCA (Foreign Account Tax Compliance Act) legislation that allows Canadian…