International Tax
International Tax & Cross-Border Areas of Practice
If, you are in need of international tax or cross-border tax advice please view the list below. If, you do not find your specific international tax issue or situation please call an international tax advisor for further information.
International Tax Retirement Planning:
▪ Cash Flow Projections for international tax liability
▪ RRSP Conversion Decisions for cross-border tax
▪ International Pension Plan Decisions
Inbound International Tax Planning:
• Tax planning for Immigration to Canada
• Tax planning for Returning Canadian Expatriates
• Investment in Canadian Businesses and Real Estate by Nonresidents
• Nonresidents Carrying on Business in Canada
• Canadian Subsidiaries of Foreign Corporations
• Tax Treaty Issues
Outbound International Tax Planning:
• Tax Planning for Emigration From Canada
• Post migration Expatriate Issues
• Investment by Canadians in Foreign Businesses and Corporations
• Investments by Canadians in Foreign Real Estate
Cross-Border Corporate Tax Planning:
• Corporate Reorganizations
• Incorporation of Unincorporated Businesses and International Holding Co.
• Minimizing Tax on the Sale of Shares of Corporations by Using the “capital Gains Exemption”
• Minimizing Tax on the Sale of Shares of Corporations by using “Safe Income Strips”
• Utilizing Corporate Tax Losses
• Partnership Formation, Reorganization, and Dissolution
• Optimizing Dividend / Salary Policy
• Maximizing the use of the “Small Business Deduction”
• Rolling over shares to Holding Companies
• Creditor Proofing Reorganizations
• Structuring Shareholder Buy / Sell Agreements
• Advising Foreign Corporations Operating in Canada
• Advising Canadian Corporations Operating Outside of Canada
International Estate Planning & Taxes:
• Estate “Freezing” of Private Corporations so that tax on death is minimized
• Reviewing and Advising on wills in order to avoid tax pitfalls and minimize taxes payable on death
• Advising in connection with the formation and terms of family trusts created during the lifetimes of individuals
• Planning aimed at minimizing exposure to probate fees on death
• Planning aimed at minimizing exposure to U.S. estate taxes
• Postmortem Planning Aimed at Avoiding Double Taxation in Connection with Shares of Private Corporations Owned on Death
• Planning Issues Regarding Corporate Owned Life Insurance
• Structuring Shareholder Buy / Sell Agreements
Real Estate & Tax Planning Abroad:
• Ownership structures Regarding Acquisition of Real Estate Abroad
• Minimizing or Deferring Tax on Real Estate Gains
• Maximizing Utilization of Tax Losses
• International Tax Structuring Joint Ventures or Syndication
• Capital Gain Versus Income Determinations
• Principal Residence Issues
• Nonresident Investment in Canadian Real Estate
• Canadian Investment in Foreign Real Estate
• Creditor Proofing Real Estate Holdings
US & Canada Cross-Border Tax Preparation, Planning and Compliance:
• General US and Canada Crossborder Tax Planning
• Relocation and Immigration Planning to Canada from the US or Vice Versa
• Income Tax and Stock Options planning for US Citizens Residing in Canada
• Client Representation with both the US Internal Revenue Service (IRS) & Canada Revenue Agency (CRA)
• Assistance in Meeting Foreign Asset Reporting and Disclosure Requirements
Services for US Citizens and Green Card Holders:
• Assistance in Citizenship Renunciation, Expatriation Consulting and Compliance
• US Tax Planning for Ownership or Beneficial Interests of Non US Corporations, Trust and Partnerships
• US and Canada Cross-border Estate Planning
• US Tax Planning in the Event of Marital Separation
• Certification Applications for the Disposition of Taxable Canadian Property by non-Canadian Residents
• US Tax Planning for Ownership of Canadian Business Interests
US Tax Amensty under the New Streamlined Filing Compliance Procedures:
• Introduced on September 1, 2012
• Catch Up Tax Returns Package for Delinquent US Citizens and Green Card Holders
• Eligible for Non-resident US Taxpayers with Low Compliance Risk
• IRS will not Assert Penalties
US Tax Filing under the Offshore Voluntary Disclosure Initiative (OVDI):
• Catch Up Tax Returns Package for Delinquent US Citizens and Green Card Holders
• Liaise Between the Internal Revenue Service and the Taxpayers on the Submission Under the OVDI
Services for Canadian Citizens, Residents and Other Non US Residents:
• US Tax Advice on the Various Ownership Structures in US Real Estate Investment
• US Tax Planning for “Snowbirds” or Future “Snowbirds”