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Avoiding Canadian Tax when Licensing Software into Canada

When software companies license or “sell” into Canada from abroad, there is often some leeway in how they allocate their fees between the ...
Feb 2024
Article

Investing in U.S. LLCs: The Canadian Perspective

Canadians investing in the U.S. are frequently asked do so through U.S. limited liability companies (LLCs). Unfortunately, while this structure works ...
Jul 2023
Article

Deferred Payment on the Sale of Owner-Managed Businesses

Deferred payment on the sale of an owner-managed business is commonplace. Getting it right, however, by addressing the issues across a range of legal ...
Jul 2023
Article

Investing in Early-Stage Ventures: The Questions That Everyone Should Ask

Broadly speaking, there are two schools of thought when it comes to investing in early-stage ventures. There is the “same boat” approach w...
Jul 2023
Article

Buying and Funding Canadian Companies: The Foreign Buyer’s Perspective

As a foreign purchaser of Canadian shares or business assets, simple steps may be taken today to reduce consequent costs tomorrow. Looking ahead pays ...
Jul 2023
Article

Minimizing the Income Tax Consequences of Sending Employees to Canada

When a foreign employer sends its employees to Canada, that employer must consider its own income tax position as well as that of its employees. The f...
Jul 2023
Article

The Advantages and Disadvantages of Purchasing Real Estate Using a Holding Company

What is a Holding Company? A holding company is a company that does not carry on business. It sells no goods and provides no services. Instead, it typ...
Dec 2022
Article

Flow-Through Shares for Canada's Innovation Sector?

What is to be done for Canada’s innovation sector when our banks are the most risk averse in the OECD, our venture capitalists venture little an...
Oct 2016
Article

Tax Loopholes: Devious Dealings or Dumb Drafting?

Original published on LinkedIn This week’s announcement that Ottawa is closing a loophole which allows non-residents of Canada to claim the prin...
Oct 2016
Article

Tax Traps of US Business Travel

The next time you travel to the US and a customs official asks whether your purpose is business or pleasure, consider the consequences. Outside the U....
Mar 2016
Article

MEDICINE PROFESSIONAL CORPORATIONS

The use of corporations by doctors and lawyers is a relatively recent regulatory concession. Historically, medicine and law were considered more vocat...
Jan 2015
Article

U.S. Estate Tax: Don’t Just Throw Your Vacation Home into a Trust

Too little attention is paid to cross-border tax traps. Even when advice is sought, the response is often incomplete or simply wrong because it is res...
Nov 2014
Article

Taxing Virtual Money: The Bitcoin and the CRA

New business remains subject to the old taxes. Believing otherwise is wishful thinking. The latest tax topic in the world of technology is the Bitcoin...
Feb 2014
Article

Canadian and Ontario Film and Television Tax Credits

View the chart here: Canadian and Ontario Film and Television Tax Credits (Chart)   Patrick is a corporate/commercial and tax lawyer of more than...
Oct 2013
Article

Animation Outsourcing and the Ontario Computer Animation and Special Effects Tax Credit (OCASE)

Tax credits represent one of the most confusing aspects of operating an animation production company; and, within the morass of jargon, rules and pape...
Jul 2013
Article

The Taxation of IP in a Nutshell

The tax aspects of holding, selling and licensing intellectual property may appear at first instance to be a confusion of rules further obscured by th...
Mar 2013
Article

The New FAD: Canada’s Foreign Affiliate Dumping Rules in a Nutshell

Much of a detailed and technical nature has been written about the new so-called Foreign Affiliate Dumping Rules. But what, in plain English, are thes...
Nov 2012
Article

Avoiding GST on the Importation of Software

A non-resident who sells software into Canada may be required to levy Canada’s Goods and Services Tax (“GST”—Canada’s VA...
Aug 2012
Article

Canadian Principal Residence Designations by Non-Residents of Canada

Canada’s exemption from tax on the sale of a principal residence is not just for Canadian residents. Non-residents of Canada enjoy one year of t...
Jun 2012
Article

Canada: The New Thin-Cap: Lenders Take Heed!

Canada's thin-capitalization rule has changed. Intra-group loans into Canada must be reviewed if adverse tax consequences are to be avo...
May 2012
Article

Selling Canadian Assets: When are s. 116 certificates Wanted and How are they Had?

Non-residents of Canada who sell Canadian assets must determine whether such sale gives rise to a Canadian tax liability. If it does, it is important ...
May 2012
Article

Canada’s Federal Sales Tax—An Overview for Non-Resident Suppliers

Those who sell goods or services in Canada have always to consider whether to become a ‘registrant’ under Canada’s federal Excise Ta...
May 2012
Article

The Life and Times of Canada’s ULC

The Origin ... The unlimited liability company is an archaic form of corporation tracing its origins back to the United Kingdom’s Companies Act...
Apr 2012
Article

Structuring Entry Into the Canadian Market: A Corporate Tax Primer

It is critical for non-residents to obtain proper Canadian legal advice respecting their long-term tax position before entering the Canadian market. T...
Jan 2012
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