MaryAnne typically advises clients on corporate and individual tax planning, tax-effective estate planning, purchase and sale of business, business succession planning and dispute resolution with the Canada Revenue Agency. She has experience working with Corporations, not-for-profits, charities, and trusts.
Based in Edmonton, MaryAnne practices throughout Alberta.
MaryAnne assists individuals, private corporations, public entities, not-for-profits, partnerships and other entities ensure they are structured in a tax efficient manner, helping her clients meet the goals of their stakeholders. Effective tax planning is especially key when transferring a business to a new owner or the next generation. MaryAnne:
•Regularly advises clients on the sale of a business on a tax-effective basis focusing on maximizing the after-tax proceeds to the client.
•Regularly assists clients in organizing their estates to ensure that their assets pass to the appropriate persons on a tax-effective basis; this often involves the use of a holding company and a family trust.
•Regularly assists clients on the intergenerational transfer of a family business on a tax effective basis, often undertaken in conjunction with the clients overall estate planning needs.
•Assists U.S. entities on appropriately structuring Canadian investment from a tax perspective.
•Assists businesses determine the most efficiently ways to comply with their GST obligations.
•Assists professionals in establishing tax-efficient corporate structures, including professional corporations, partnerships, and cost-sharing arrangements.
•Assists farmers and their estates in the tax-efficient transfer of farm property.
•Assists employers in establishing retirement plans, stock option plans, and other benefit programs for employees.
•Assists employees in maximizing their tax-efficiency in preparation for retirement.
MaryAnne has a reputation for problem solving and enjoys assisting clients faced with tax disputes at all phases, from audit to court. She takes an economical approach to the law, helping her clients evaluate risks and make the right business decisions.
Having articled with the Department of Justice and Public Prosecution Service of Canada, MaryAnne has experience working with tax officials and on behalf of the CRA which helps her to obtain the most economical solutions to her client's tax problems. She has successfully resolved files with justice lawyers and has appeared before the Tax Court of Canada, the Provincial Court, the Alberta Queen’s Bench Master’s Chambers, the Justice Chambers, and the Employment Insurance Umpire.
Her experience in tax disputes includes:
•Negotiated a settlement with the Department of Justice relating to a situation where a taxpayer had been defrauded by their accountant.
•Represented a taxpayer in a dispute regarding where the workers were independent contractors or employees.
•Represented a taxpayer through the audit process in a situation where complications were anticipated.
•Negotiated a settlement with the Department of Justice relating to a reassessment for the capital gains on the principle residence of a deceased individual which resulted in the saving of hundreds of thousands of dollars.
•Assisted an accounting corporation after they received a third party notice requiring them to provide a substantial number of tax-related documents; she worked with the parties involved to reach a settlement which enabled them to comply with the Canada Revenue Agency while protecting their interests.
•Represented taxpayer disputes with the Canada Revenue Agency relating to whether a corporation was a personal service business, whether expenses were valid, and other corporate tax disputes.
•Represented taxpayer disputes with the Canada Revenue Agency relating to payroll and GST accounts.
•Prepared submissions to the appeal's division for a real estate development's multimillion dollar tax dispute.
•Assisted individuals and corporations with the preparation of submissions for the Canada Revenue Agency voluntary disclosure program.
•Obtained rectification orders correcting inadvertent errors that resulted in unintended tax consequences saving clients thousands of dollars of additional taxes.
•Prepared application for taxpayer relief which resulted in Canada Revenue Agency waiving hundreds of thousands of dollars
Charities and Not-for-Profit Organizations
As both a corporate and tax lawyer, MaryAnne provides charities and not-for-profit organizations with the expertise to effectively and efficiently deal with the CRA, establish good governance, and handle their affairs. MaryAnne has extensive experience assisting charities become registered with the CRA, assisting charities and not-for-profits to comply with their obligations under the Income Tax Act and provincial legislation, and representing charities in disputes with the Charities Department.
•Provides tax advice on the aspects and advantages of setting up charitable foundations.
•Works with organizations to assist them with incorporation and charitable registration applications.
•Provides structuring governance solutions for charitable and not-for-profit organizations.
•Works with charities to craft bylaws and purposes that comply with both the Income Tax Act and provincial legislation.
•Assists charities in meeting their obligations as registered charities under Income Tax legislation.
•Assisted a large charity in an audit of their lease and rental agreements and established a standardized agreement for them to use on a go-forward basis.
•Assisted registered charities in disputes with the Charities Directorate over the eligibility of certain payments for donation tax receipts.
•Assisted organizations with the preparation of charitable trust agreements, articles, bylaws and applications for registration as a charity with the Canada Revenue Agency.
Publications & Presentations
•“New Trust Reporting Requirements - Big Implications? ” MaryAnne Loney and Mike Harris, McLennan Ross Wills & Estates Blog, 2018
• Budget 2018 - Legislation Affecting Private Corporations - The Passive Investment Income Measures MaryAnne Loney and Mike Harris, McLennan Ross E-Mail Alert, 2018
• Five Tax Action Items for 2018 MaryAnne Loney and Mike Harris, McLennan Ross E-Mail Alert, 2018
• Finance Releases Updated Legislation to Limit Income Splitting MaryAnne Loney and Mike Harris, McLennan Ross E-Mail Alert, 2017
• Update on July 18th Proposed Tax Changes Affecting Private Corporations MaryAnne Loney and Mike Harris, McLennan Ross E-Mail Alert, 2017
• Is This the End of Tax-Motivated Family Trusts? , McLennan Ross E-Mail Alert, 2017
• Estates May Need to Take Steps to Trigger Losses During First Year, McLennan Ross E-Mail Alert, 2017
• New Principal Residence Exemption Rules, McLennan Ross E-Mail Alert, 2017
• Employees, Contractors, Partners, the Government: You Have Obligations to All of Them, Alberta Doctor Digest, 2016
• A Director’s Resignation Must Be Signed and Delivered, McLennan Ross E-Mail Alert, 2016
• Amalgamating Your Two Professional Corporations - The Time is Now, McLennan Ross E-Mail Alert, 2016
• Should You Consider Amalgamating Your Two Professional Corporations?, McLennan Ross E-Mail Alert, 2016
• Changes to the Income Tax Act Place New Risks on Intercorporate Dividends, McLennan Ross Legal Counsel Newsletter, 2015
• Bad News for Testamentary, Spousal Trusts, The Lawyers Weekly, 2015
• Significant Tax Changes to Estate Trusts, McLennan Ross E-Mail Alert, 2015
• Alternate Forms of Executive Compensation: Tax and Employment-Related Issues and Trends, McLennan Ross Webinar, 2018
• Estate & Business Succession Planning, McLennan Ross Webinar, 2016
Professional Associations, Affiliations and Community Activities:
•Executive Member, Canadian Bar Association - Tax Section
•Member, Canadian Tax Foundation
•Member, Edmonton Tax Discussion Group
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