Kim Resources@2x

Kim G C Moody’s 1-1-1 Musings For July 19, 2023

One Comment About Taxation

There are only two countries in the world that we know of that impose personal taxation on a citizenship basis:  the United States and Eritrea (a small country on the Horn of Africa).  In 2010, in a bid to enforce its taxation rules on its expats, the U.S. introduced “FATCA” which imposes rules for “foreign financial institutions” – like Canadian banks and insurance companies – to report to the U.S. any of its account holders who have indicia of U.S. citizenship.  In 2014, Canada introduced domestic legislation under Part XVIII of the Income Tax Act and entered into an Inter-governmental agreement (“IGA”) with the U.S. to help enforce FATCA.  One Canadian resident – who is also a U.S. citizen – challenged the Canadian constitutionality of Part XVIII several years ago in the Federal Court.  The taxpayer was not successful and therefore appealed to the Federal Court of Appeal (“FCA”).  In 2022, the FCA released its decision, and the taxpayer was once again not successful.

Last week, the taxpayer’s application to the Supreme Court of Canada for the Court to hear its appeal was denied.  Accordingly, FATCA is alive and well in Canada.  And U.S. citizens who are residents of Canada will continue to be saddled with very complex and onerous U.S. filings and reporting requirements while also filing Canadian returns.  One of my colleagues and I wrote about this last week for Moodys Private Client and it can be viewed here.  Overall, if you are a U.S. citizen who is also a resident of Canada and you have been ignoring your U.S. filings, – don’t do that.  Get up to speed with careful legal advice soon!


One Comment About Leadership

Good leaders are intentional about what kind of leaders they want to be, what their style is, what kind of culture they want to build and what kind of legacy they want to leave.  In addition, good leaders are intentional about drawing the most out of their teammates and ensuring that their individual “purposes” are identified and cultivated.  The landmark 1946 book – Man’s Search For Meaning – by Viktor Frankl is a brilliant book that discusses the fact that for a person to have meaning in their life, they must have a purpose.  Viktor Frankl was a psychiatrist who survived the Auschwitz Concentration Camps.  Besides being a memoir, the book discusses, from a psychiatric perspective, why some prisoners quickly died upon entering the camps vs others who lived much longer or survived.  The conclusion: those that created a purpose upon entering the camps – no matter how small the purpose – had a much better chance of surviving and maintaining hope.  Leaders, read the book….it changed my life and helped me to be a better and more empathetic leader.


One Comment About Economics / Public Policy

An interesting paper was released last week by Philip Cross for the Fraser Institute entitled What is Behind Canada’s Growth Crisis?  It discusses that weak growth has persisted in Canada for nearly a decade, with recent per capita GDP growth being the lowest in almost 100 years.  This is a crisis in Canada which, if it is not addressed, can ultimately impact the very social fabric of our country.  The paper discusses the fact that Canada has recently focused more on income re-distribution rather than helping to create income.  A key paragraph from the executive summary of the paper is as follows:

Recent research, however, stresses the importance of a nation’s culture to economic growth. Without a culture that supports entrepreneurship and innovation, even the best policies and institutions will produce disappointing results.  Canadians need to dispense with the mindset that, in the words of a leading commentator, “in Canada, if you run a successful business, you are made to feel that you have done something wrong.”

Absolutely.  Our country’s entrepreneurs need to be celebrated.  Not vilified.

I’d encourage you to read Mr. Cross’ paper.


Bonus Comment – A Quote About Entrepreneurship

Joe Lonsdale stated the following:

Entrepreneurship is, in large part, about building something from nothing, which means creating a cause.

 Agreed! I truly respect all entrepreneurs for creating something out of nothing, creating a cause, taking risks and their important role in building communities and culture.  Again, entrepreneurs need to be celebrated.  And the Canadian government should ensure our economic garden is fertile for them to plant their seeds.


That’s it for this edition of 1-1-1….I hope you enjoyed it.  If you haven’t signed up for our mailing list yet, please do so!

Click HERE to join.