The US Government has required its citizens to report on their foreign bank accounts since 1970; however, its controversial revisions of October 2008 continue to cause tax practitioners, citizens and persons doing business in the US headaches.  We expect the US Government to aggressively enforce these reporting requirements since they assist the US Government in identifying abusive offshore accounts such as the UBS accounts (discussed in our blogs on September 8, 2009 and February 10, 2010).

On March 4, 2010, Federal Finance Minister Jim Flaherty released the 2010 Federal Budget (the "Budget").  The Budget contained a significant amount of tax material in comparison to recent budgets.  Find below the relevant tax measures that are worthy of discussion. 

First off, what an Olympics!  As a proud Canadian, yesterday will certainly go down in the memory banks as one of the most significant days in Canadian sports history.  Vancouver did an amazing job hosting the Olympics and did Canada proud.  Of course, many of us were interested in the Canadian men's hockey team result and watching the game was a "pins and needles" exercise but when Sidney Crosby scored the overtime goal what a rush of excitement!  Oh Canada!!

Further to our blog postings of November 26, 2009 and October 27, 2009, this legislation was finally proclaimed on February 4, 2010 and comes into force on March 1, 2010. 

The tax world moves quickly. This blog entry will highlight a few miscellaneous updates that are of relevance to most of our friends and clients.

In the recent decision of Collins v. The Queen, the Federal Court of Appeal clarifies the meaning of "an amount payable in respect of the year" - one of the requirements for interest deductibility under paragraph 20(1)(c) of the Income Tax Act (the "Act").  Specifically, in order for interest to be deductible under paragraph 20(1)(c) of the Act, there must be: